Vol. 29 No. 2 - Winter 2010

Opinion Points

Taxation

Tax Shelters: Up Off the Canvas?

Steve R. Johnson

Recently, taxpayers prevailed at trial in two federal tax shelter cases: TIFD III-E Inc. v. United States, 2009 wL 3208650 (D. Conn. oct. 7, 2009) (“Castle Harbour III”), and Consolidated Edison Co. v. United States, 2009 wL 3418533 (Fed. Cl. oct. 21, 2009) (“Con Ed”). ...

Taxation

Saving Private Ryan’s Tax Refund: Poverty Relief for ALL Working Poor Military Families

Francine J. Lipman

The lower ranks of the armed services are part of an exploding population of working poor in America. The U.S. Department of Defense estimates that thousands of military families live in poverty and that 40% of lower ranked soldiers face “substantial financial difficulties.” ...

From the Chair

Taxation

From the Chair

Stuart M. Lewis

Of the many activities that the Section undertakes, its pro bono efforts have to be some of the most impressive and important. Over the last few months I have begun to appreciate these activities to a much greater extent. Members of the Section should seriously consider increasing their involvement in one or more of these programs. ...

Interview

Taxation

Gilbert S. Rothenberg

Jasper L. Cummings, Jr. and Alan J.J. Swirski

Gilbert Rothenberg is the Chief of the Appellate Section of the United States Department of Justice’s Tax Division. He is also currently serving as Acting Deputy Assistant Attorney General for Review and Appellate. ...

Points to Remember

Taxation

Service Issues Guidance on Section 877A Exit Tax

Michael A. Spielman

In June 2008, a new expatriation provision, section 877A, was enacted by the Heroes Earnings Assistance and Relief Tax Act of 2008 (“HEART”). Section 877A applies to certain individuals who, on or after June 17, 2008, relinquish their U.S. citizenship or cease to be a lawful permanent resident of the United States. ...

Taxation

Employee Benefit Plans: Recent Developments

David Pratt

Temporary Waiver of Required Minimum Distribution Rules. Under the Worker, Retiree, and Employer Recovery Act of 2008 no required minimum distribution (RMD) was required for calendar year 2009 from IRAs and employer-sponsored defined contribution plans, including governmental 457(b) plans. ...

Taxation

IR S Directive on Outer Continental Shelf Activity

Heather M. Pesikoff and Dan Boeskin

The Service’s Large and Mid-Size Business division has issued a new directive regarding foreign taxpayers engaged in activities related to the exploration for, or exploitation of, natural resources on the Outer Continental Shelf in the Gulf of Mexico (“OCS”). ...

Taxation

Deducting Mixed-Use Vacation Home Expenses: Uncertainty in the Taxpayer’s Favor

Vlad Frants

You have been consulted by a taxpayer, who owns a two-bedroom vacation home. The taxpayer rents it to tenants for 90 days during the year and receives $9,000 of rental income. The taxpayer uses the vacation home personally for 30 days during the year. ...

Tax Bites

Taxation

Tax Bites in the 111th Congress

Gail L. Richmond

Many tax statutes include “Revenue Act” in their titles. It’s an accurate descriptor, but oh so dull. Fortunately for our readers, many legislators understand the importance of creative naming. This Tax Bites presents an assortment of bills introduced in the early months of the current Congress. ...

News Briefs

Taxation

News Briefs

ABA Section of Taxation

ABA Tax Section news and announcements.

Boxscore

Taxation

Boxscore

ABA Section of Taxation

Since September 2009, the Section has coordinated the following government submissions, which can be viewed and downloaded free of charge from the Section’s website.

Renew Your ABA Membership

Vol. 29 No. 2 - Winter 2010

NewsQuarterly, Vol. 29 No. 2

Opinion Points

Tax Shelters: Up Off the Canvas?

Saving Private Ryan’s Tax Refund: Poverty Relief for ALL Working Poor Military Families

From the Chair

From the Chair

Interview

Gilbert S. Rothenberg

Points to Remember

Service Issues Guidance on Section 877A Exit Tax

Employee Benefit Plans: Recent Developments

IR S Directive on Outer Continental Shelf Activity

Deducting Mixed-Use Vacation Home Expenses: Uncertainty in the Taxpayer’s Favor

Tax Bites

Tax Bites in the 111th Congress

News Briefs

News Briefs

Boxscore

Boxscore

ABA Resources

The ABA

Connect

Renew Your ABA Membership

American Bar Association TM American Bar Association

Vol. 29 No. 2 - Winter 2010

NewsQuarterly, Vol. 29 No. 2

Opinion Points

Tax Shelters: Up Off the Canvas?

Saving Private Ryan’s Tax Refund: Poverty Relief for ALL Working Poor Military Families

From the Chair

From the Chair

Interview

Gilbert S. Rothenberg

Points to Remember

Service Issues Guidance on Section 877A Exit Tax

Employee Benefit Plans: Recent Developments

IR S Directive on Outer Continental Shelf Activity

Deducting Mixed-Use Vacation Home Expenses: Uncertainty in the Taxpayer’s Favor

Tax Bites

Tax Bites in the 111th Congress

News Briefs

News Briefs

Boxscore

Boxscore

ABA Resources

The ABA

Connect