From the Chair: Stanley L. Blend
The ﬁrst quarter of 2008 has been a very productive one for the Section.
NewsQuarterly Section of Taxation Vol. 27 No. 3 Spring 2008 *Miller & Chevalier Chartered, Washington, DC. continued on page 11 For improper payments made through a foreign subsidiary, the u.S. tax consequences will depend on the ownership form used. the u.S. tax consequences that result when a controlled foreign corporation (CFC) makes an illegal payment to a foreign government official or employee are discussed below. For further discussion regarding the u.S. tax consequences of improper...
In the last several years, multinational companies have become the subject of increased scrutiny for violations of the Foreign Corrupt Practices Act (FCPA) in the U.S. and similar antibribery and anticorruption laws in foreign countries.
The American Jobs Creation Act of 2004 (the “2004 Act”) and the Gulf Op-portunity Zone Act of 2005 (the “2005 Act”) made several changes to sections 1361, 1362, and 1366.
Recently, the Third Circuit reversed the Tax Court’s 2006 decision in Swallows Holding v. Commissioner, and upheld the validity of Treasury Regulations promulgated under section 882 that require a foreign corporation to ﬁle timely returns to receive the beneﬁt of deductions otherwise allowed.
The American Bar Association’s (“ABA”) Model Rules of Professional Responsibility (the “Model Rules”) have been adopted, with some modiﬁcation, in the vast majority of states and, therefore, provide useful baseline guidance to all attorneys, including tax attorneys working for both private clients (inside or outside) and the government.
Created in 2007, the mission of the Tax Section’s new Publications Committee is to lend focus to and develop the Section’s publishing program in order to provide high quality information on tax law and practice and to serve the needs of Section members, the tax profession, and the general public in a manner that enhances the reputation of the Section and generates revenues.
This year, the ABA Section of Taxation is proud to present its Janet Spragens Pro Bono Award to Joseph Barry Schimmel, Cohen, Chase, Hoffman & Schimmel, Miami, Florida. With this award, established in 2002, the Tax Section recognizes one or more individuals or law ﬁrms that have provided meritorious pro bono service in the representation of low-income taxpayers.