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Vol. 32 No. 3 - Spring 2013


Points to Remember

International Tax: A Quest to Resolve Overlap Between Foreign Base Company Sales and Foreign Base Company Services

The classification of a controlled foreign corporation’s (CFC) gross income as either foreign base company sales income (FBCSI) or foreign base company services income (FBCSvI) is often uncertain, and yet proper characterization may be crucial to its U.S. tax implications. This article explores the potential overlap between these two types of Subpart F income, including the causes and consequences of the current uncertainty as well as a possible resolution thereof. ...

Section Meetings Calendar

From the Chair


Opinion Point

Restaurant Week Re-examined: A Month of Eating Within the IRS Collection Financial Standards

A few months ago, I was sitting at a reasonably casual restaurant in Chicago’s West Loop, waiting for one of my favorite burgers in the city. Two prime beef patties, lightly-toasted bun freshly made from a local bakery, topped with an over easy egg (perfect burger-to-egg-to-bun ratio), $10. I washed it down with one of those fancy microbrews, $9. Including tax and tip, it was almost a $25 weeknight dinner. ...

Report of the Nominating Committee

Pro Bono Matter

In Honor of Carlton Smith— Co-Recipient of the 2013 Janet R. Spragens Pro Bono Award

In 1997, Janet Spragens testified before the IRS Restructuring Commission about the need for legal representation in light of changes in national welfare and tax laws that put increasing pressure on the tax system. Janet directed the tax clinic at American University’s Washington College of Law (since named in her honor), and her writing, testimony and good works at the ABA contributed to many efforts that improved the tax system for lower-income taxpayers. ...

Committee Spotlight


CLE Calendar

Law Student Tax Challenge