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Selected Publications
BNA Tax Management Portfolio, 545 T.M., Equipment Lease
Characterization (1st ed. 1996; 2nd ed. 2009, forthcoming).
Comprehensive analysis of when
a transaction involving the use of property constitutes a sham,
lease, loan, partnership, service contract or estate for years for
U.S. federal income tax purposes.
Disputing Rev. Rul. 99-14: Pre-Tax Profit, Defeasance, and
Circular Leases, 83 Tax Notes 557-571 (April 26, 1999).
Analysis of the 1999 IRS
ruling that holds lease-in lease-out transactions are shams.
Applying Sections 704(b) and 751(b) to Two Structures for
Shifting Partnership Allocations, Taxes--the Tax Magazine, Vol.
67, Nos. 10 & 11, pp. 635-74, 741-59 (Oct. & Nov. 1989).
Structuring Foreign Investments in U.S. Corporations Using
Portfolio Debt Guaranteed by the Issuer's Foreign Affiliate,
International Tax & Business Lawyer, Vol. 6, No. 2, pp. 398-455 (Spr.
1988).
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