Publications

Searched Practice: Tax

"‘Rodriguez’ Holds Section 951 Inclusions Not Qualified Dividend Income; CFC Components of Proposed Rules Under Section 1411 Now Unlikely to Change," Bloomberg BNA's Daily Tax Report (7/26/2013)
Jason Yen Author

"Data Privacy and the Foreign Account Tax Compliance Act," Covington E-Alert (2/14/2013)
Daniel Cooper Co-Author, Dirk Suringa Co-Author

"District Court’s ‘AIG’ Ruling Expands Application of Economic Substance Doctrine In Unexpected Ways for Transactions Generating Excess Foreign Tax Credits," Bloomberg BNA Daily Tax Report (2013)
Jason Yen Co-Author, Patrick Sigmon Co-Author

"Sixth Circuit Holds Severance Pay for Layoffs Not Subject to FICA Taxes," Covington E-Alert (9/7/2012)
Emin Toro Co-Author, Robert Newman Co-Author, Richard Shea Co-Author

"FATCA and CLOs - A Primer," Covington Advisory (8/14/2012)
Dirk Suringa Co-Author, Philipp Tamussino Co-Author

"Virtual Contract Manufacturing: The Last Frontier?," Tax Notes International (7/9/2012)
William Chip Author

"Global Mobility," Webinar (6/12/2012)
Chris Bracebridge, Guy Dingley

"CBP Finalizes Ruling Allowing Post-Importation Pricing Adjustments," Covington E-Alert (6/5/2012)
David Grace Co-Author, Emin Toro Co-Author, Reeves Westbrook Co-Author

"An Opportunity to Support US Customs Valuations," International Tax Review (June 2012)
David Grace Co-Author, Emin Toro Co-Author

"What’s New in the Technical Taxpayer and §909 Guidance," Tax Management International Journal (5/11/2012)
Dirk Suringa Co-Author, Caitlyn Jacobs Co-Author

"The Mystery of Intangibles," Tax Management International Journal (5/11/2012)
William Chip Author

"IRS and Treasury Release Proposed FATCA Regulations," Covington E-Alert (2/13/2012)
Dirk Suringa Co-Author, Gregory Frischmann Co-Author

"Limited Liability Partnerships and Employment Law," Covington E-Alert (February 2012)
Christopher Walter Co-Author, Robin Wolfenden Co-Author, Guy Dingley Co-Author

"Grandfathered Tax Strategy Patents," 3 Colum. J. Tax L. Tax Matters 7 (2012)
William Paul Author

"From the Chair (On Professionalism)," ABA Tax Section News Quarterly (Fall 2011)
William Paul Author

"The More Things Change, The More They Stay The Same — Part II," Covington E-Alert (7/11/2011)
Kevin Shortill Co-Author, Robert Kelner Co-Author, Robert Lenhard Co-Author

"FBAR Filing Deadline Extended for Certain US Persons," Covington E-Alert (6/7/2011)
Dirk Suringa Co-Author, Mark Plotkin Co-Author, Michael Nonaka Co-Author

"Notice 2011-34 – New Guidance on FATCA Reporting & Withholding Requirements," Covington E-Alert (4/15/2011)

"FBAR Final Regulations Expand Reporting Requirements," Covington E-Alert (3/29/2011)
Dirk Suringa Co-Author, Mark Plotkin Co-Author, Michael Nonaka Co-Author

"Recent IRS Guidance Concerning Section 48C Manufacturing Credit Reminds that Standard for a "Significant Change" is Low, but Indicates Willingness to Consult with DOE on Whether Changes are Significant," Covington E-Alert (1/5/2011)
Daniel Luchsinger Co-Author, Lindsay Kitzinger Co-Author

"IRS Makes Changes to Uncertain Tax Position Reporting Proposal," Covington E-Alert (9/29/2010)
Jeremy Spector Co-Author, Emin Toro Co-Author

"DC Circuit Upholds Application of Attorney Work Product Doctrine to Information Disclosed to Auditors," Covington E-Alert (6/30/2010)
Emin Toro Co-Author, Reeves Westbrook Co-Author

"Carried Interests," Covington E-Alert (6/1/2010)

"The American Jobs and Closing Tax Loopholes Act of 2010 - Expected and Unexpected International Proposals," Covington E-Alert (5/20/2010)
Daniel Luchsinger Co-Author, Dirk Suringa Co-Author, Lindsay Kitzinger Co-Author

"Government Incentives For Renewable Energy - An Update," Covington Advisory (3/16/2010)
Daniel Luchsinger Co-Author, Dirk Suringa Co-Author

"Recent Treasury Guidance On Foreign Bank Account Reports," Covington E-Alert (3/8/2010)
Dirk Suringa Co-Author, Mark Plotkin Co-Author, Michael Nonaka Co-Author

"Application Process Opens for Qualifying Advanced Energy Project Tax Credits," Covington E-Alert (8/18/2009)
Daniel Luchsinger Co-Author

"Exchange-Traded Notes," Taxation of Financial Products & Transactions (PLI) (2009)
William Paul Author

"Summary of Tax Provisions in the Emergency Economic Stabilization Act of 2008," Covington E-Alert (10/7/2008)
Daniel Luchsinger Co-Author, Michael Nonaka Co-Author

"Structuring the Scope of Work - Tax Issues©," The International Contract Manual (West, a Thomson Reuters Business) (2008)
William Chip

"Contingent Swaps," Federal Bar Association/IRS Insurance Tax Seminar (6/1/2006)
William Paul

"New Legislation Imposes No-Fault Penalty on Tax-Exempt Organizations Participating in Tax Shelters and Similar Transactions," (5/12/2006)
William Paul Co-Author, Kevin Shortill Co-Author

"Courts Grant IRS Refunds of Federal Excise Taxes on Long-Distance Communications," Covington E-Alert (6/9/2005)

"After the Acquisition: Tax Planning for Business Integration," International Tax Review (April 2004)
William Chip

"Contingent Swaps: A Critique of Revenue Ruling 2002-30," 16 J. of Tax. of Financial Institutions 17 (March/April 2003)
William Paul Author

"Final Qualified Covered Call Regulations Resolve Some Issues, But Raise New Ones," Journal of Taxation of Financial Institutions, Vol. 15/No. 6 (8/1/2002)
William Paul Author

"Contingent Swaps: Rev. Rul. 2002-30 and Beyond," Financial Products Committee, D.C. Bar Tax Section (7/23/2002)
William Paul

"Financial Products Developments," Insurance Tax Seminar, FBA/IRS (6/21/2002)
William Paul

"Current Developments in the Taxation of Financial Products," Financial Transactions Committee, ABA Tax Section (5/10/2002)
William Paul

"Are Repos Really Loans?," Tax Analysts (May 2002)
William Chip

"Current Tax Developments Affecting Mutual Funds," 37th Annual Mutual Funds & Investment Management Conference (3/27/2002)
William Paul

"Stock Futures Legislation Creates Instability in Tax Status of Index Options and Futures," Journal of Taxation of Financial Institutions, Vol. 15/No. 2 (11/1/2001)
William Paul Co-Author

"IRS Proposes to Expand and Contract Scope of Qualified Covered Call Exception to the Straddle Rules," Journal of Taxation of Financial Institutions, Vol. 14/No. 6 (7/1/2001)
William Paul Co-Author

"New Developments in Equity Derivatives," Structured Finance Institute Conference - Presentation Notes (6/1/2001)
William Paul Author

"OECD Transfer Pricing Guidelines," Transfer Pricing Handbook (2001)
William Chip

"Insurance Company Finds Asset Hedging Technique That Avoids Straddle Rules," Journal of Taxation of Financial Institutions, Vol. 14/No. 3 (January 2001)
William Paul Co-Author

"Administration Legislative Proposals Relating to Financial Products," Financial Transactions Committee, ABA Tax Section (5/12/2000)
William Paul

"Alternative Approaches to Concentrated Equities," National Association of Personal Financial Advisors (5/6/2000)
William Paul

"Age Discrimination in Cash Balance Plans: Another View," 19 Va. Tax. Rev. 763 (Spring 2000)
Robert Newman Co-Author, Michael Francese Co-Author, Richard Shea Co-Author

"ABC's of Financial Products," D.C. Bar/George Washington Univ. Law School Taxation Institute (10/8/1998)
William Paul

"Memorandum re: Transferable Stock Options," (4/17/1998)Covington & Burling