Volume 56, No. 4 - Summer 2003

Articles

Selected Current Effectively Connected Income Issues for Investment Funds

David R. Sicular and Emma Q. Sobol

A great deal of uncertainty currently surrounds the determination of whether the activities of certain investment funds will give rise to income effectively connected with the conduct of a trade or business within the United States for the fund itself (if a corporation) or for its non-U.S. investors. ...

The Unresolved Tax Status of Multinational Service Partnerships and Their Partners

Kimberly S. Blanchard

Multinational partnerships still a relative rarity, present many unresolved tax issues. For purposes of this article, the term MNP refers to an entity generally recognized as a partnership in two or more countries, having offices in two or more countries...

What Then To Do With a Non-Cooperative Cooperative?

Clayton S. Reynolds

This article examines the tax treatment that should be accorded an entity that, while cooperative in form, is not operating "in accordance with cooperative principles." More particularly, this article seeks to determine whether such an entity may deduct...

Joint Ventures Between Non-Profit and For-Profit Organizations St. David's Case—Worthy Destination, but Road Under Construction

Janet James Mahon

Joint ventures between non-profit organizations and for-profit organizations, particularly in the health care area, is a growing phenomenon. Initially born from the need of non-profits to obtain additional funding for charitable ventures, these ventures have proven to be financially lucrative for all entities involved. ...

Restricting the Flow of Funds from U.S. Charities to International Terrorist Organizations—A Proposal

Mindy Herzfeld

Numerous news reports since September 11, 2001 have reviewed the shortcomings within the intelligence system that may have led to the failure to prevent the terrorist attacks on the United States. In response, oversight committees have focused on the need for revamping our intelligence operations and agencies. ...

Notes

The Continuing Battle Over Foreign Tax Shelters in the D.C. Circuit: Boca Investerings Partnership v. United States

Francisco J. Navarro

In Boca Investerings Partnership v. United States, the United States Court of Appeals for the District of Columbia Circuit revisted the use of foreign tax shelters by U.S. corporations. The D.C. Circuit held that losses incurred by a U.S. company through a partnership...

Section 6321 Tax Liens on Tenancies by the Entirety After United States v. Craft

Kirstin O'Leary

In United States v. Craft, the United States Supreme Court addressed the application of section 6321 tax liens to properties held in tenancy by the entirety. The Court reversed the decision of the United States Court of Appeals for the Sixth Circuit by holding that...

The Difficulties of Establishing a Supporting Organization When Making Charitable Contributions to a Donor-Advised Fund Program; Lapham Foundation Inc. v. Commissioner

Joel Ugolini

In Lapham Foundation Inc. v. Commissioner, the Tax Court held that a foundation making charitable grants to a donor-advised fund program was not a private foundation because it failed to meet the criteria for a supporting organization delineated in section 509(a)(3)(B). ...

Gone Fishing! A Fishing Trip Following A Sales Meeting Is Not Tax Deductible Under Section 162: Townsend Industries v. United States

Todd A. Walter

In Townsend Industries v. United States, a federal district court held that a company's expenditures for employee fishing trips were subject to employment tax. To reach such a result, the court found it necessary to consider if the costs of the fishing trips...

Important Developments During the Year

ABA Section of Taxation

Tax Section Committee Important Developments Reports.

Index

Index to Volume 56

ABA Section of Taxation

This index includes articles, committee reports, and student notes that appear in volume 56 of The Tax Lawyer.

The Tax Lawyer

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Vol. 56, No. 4 - Summer 2003

The Tax Lawyer, Summer 2003

Articles

Selected Current Effectively Connected Income Issues for Investment Funds

The Unresolved Tax Status of Multinational Service Partnerships and Their Partners

What Then To Do With a Non-Cooperative Cooperative?

Joint Ventures Between Non-Profit and For-Profit Organizations St. David's Case—Worthy Destination, but Road Under Construction

Restricting the Flow of Funds from U.S. Charities to International Terrorist Organizations—A Proposal

Notes

The Continuing Battle Over Foreign Tax Shelters in the D.C. Circuit: Boca Investerings Partnership v. United States

Section 6321 Tax Liens on Tenancies by the Entirety After United States v. Craft

The Difficulties of Establishing a Supporting Organization When Making Charitable Contributions to a Donor-Advised Fund Program; Lapham Foundation Inc. v. Commissioner

Gone Fishing! A Fishing Trip Following A Sales Meeting Is Not Tax Deductible Under Section 162: Townsend Industries v. United States

Important Developments During the Year

Important Developments During the Year

Index

Index to Volume 56

The Tax Lawyer

Subscribing

ABA Resources

The ABA

Connect

Renew Your ABA Membership

American Bar Association TM American Bar Association

Vol. 56, No. 4 - Summer 2003

The Tax Lawyer, Summer 2003

Articles

Selected Current Effectively Connected Income Issues for Investment Funds

The Unresolved Tax Status of Multinational Service Partnerships and Their Partners

What Then To Do With a Non-Cooperative Cooperative?

Joint Ventures Between Non-Profit and For-Profit Organizations St. David's Case—Worthy Destination, but Road Under Construction

Restricting the Flow of Funds from U.S. Charities to International Terrorist Organizations—A Proposal

Notes

The Continuing Battle Over Foreign Tax Shelters in the D.C. Circuit: Boca Investerings Partnership v. United States

Section 6321 Tax Liens on Tenancies by the Entirety After United States v. Craft

The Difficulties of Establishing a Supporting Organization When Making Charitable Contributions to a Donor-Advised Fund Program; Lapham Foundation Inc. v. Commissioner

Gone Fishing! A Fishing Trip Following A Sales Meeting Is Not Tax Deductible Under Section 162: Townsend Industries v. United States

Important Developments During the Year

Important Developments During the Year

Index

Index to Volume 56

The Tax Lawyer

Subscribing

ABA Resources

The ABA

Connect