Rethinking Property, Terminations, And Gain After McKelvey, Part 2, with Robert W. Wood, Vol. 183, No. 7, Tax Notes Federal (May 13, 2024), p. 1231.
Rethinking Property, Terminations, And Gain After McKelvey, with Robert W. Wood, Vol. 183, No. 6, Tax Notes Federal (May 6, 2024), p. 1051.
Loans, Prepaid Forward Contracts, and Portfolio Funding, with Robert W. Wood, Vol. 181, No. 11, Tax Notes Federal (December 11, 2023), p. 2015.
Can Lawyers Write Off Client Costs As Current Business Expenses?, with Robert W. Wood, Vol. 180, No. 10, Tax Notes Federal (September 4, 2023), p. 1647.
Is Borrowing From Qualified Settlement Funds Taxable, with Robert W. Wood, Vol. 170, No. 4, Tax Notes Federal (January 25, 2021), p. 963.
Rescission in the Time of COVID, with Robert W. Wood, Vol. 169, No. 5, Tax Notes Federal (November 2, 2020), p. 783.
Do-It-Yourself Litigation Funding a la Novoselsky, with Robert W. Wood, Vol. 168, No. 9, Tax Notes Federal (August 31, 2020), p. 1665.
Founders and Substantial Risk of Forfeiture: What, Me, Worry?, Tax Notes Federal (July 20, 2020), p. 459.
Taxing Litigation Finance: Plaintiff, Lawyer, and Funder Tax Goals, with Robert W. Wood, Vol. 16, No. 10, Tax Notes Federal (June 8, 2020), p. 1735.
The Importance of Variable Prepaid Forward Contracts, Tax Notes Federal (April 2020), p. 121.
Blackstone and Apollo Take the Sub C Plunge, Vol. 27, No. 12, The M&A Tax Report (July 2019), p. 7.
Third Circuit Upholds CFC Guaranty Regulations, Vol. 27, No. 12, The M&A Tax Report (July 2019), p. 4.
High-Profile Lawyer Indicted for Old-School
Tax Obstruction, Vol. 27, No. 11, The M&A Tax Report (June 2019), p. 7.
Electing Deferral Under Code Sec. 83(i), Vol. 27, No. 11, The M&A Tax Report (June 2019), p. 1.
New Code Sec. 245A and Pledges of CFC Stock, Vol. 27, No. 10, The M&A Tax Report (May 2019), p. 1.
Reasonable Basis: All in the Taxpayer’s Head?, Vol. 27, No. 9, The M&A Tax Report (April 2019), p. 1.
Do Friendly Founders Really Hold Restricted Shares Subject to a Substantial Risk of Forfeiture?, Vol. 27, No. 8, The M&A Tax Report (March 2019), p. 1.
Check Your Privilege(s): Kovel, Work Product, and Third-Party Valuations, Vol. 27, No. 7, The M&A Tax Report (February 2019), p. 1.
Economic Substance and the (Foreign) Dividends Received Deduction, Vol. 27, No. 6, The M&A Tax Report (January 2019), p. 5.
New Code Sec. 83(i): Buy Now! Pay Later!, Vol. 27, No. 6, The M&A Tax Report (January 2019), p. 1.
Deals, Kill Fees, and Taxes, with Robert W. Wood, Vol. 162, No. 4, Tax Notes (January 28, 2019), p. 413.
Back to Basis: Small Tax Mistakes Can Mean Big Taxes, with Robert W. Wood, Vol. 162. No. 1, Tax Notes (January 7, 2019), p. 75.
Update: PE Firms Converting to C Corporations, Vol. 27, No. 5, The M&A Tax Report (December 2018), p. 6.
Deposed CEOs at the Gate: Poison Pills and Tax, Vol. 27, No. 5, The M&A Tax Report (December 2018), p. 1.
Upstream “C” with a Drop: Form, Substance, and Code Sec. 311(b), Vol. 27, No. 4, The M&A Tax Report (November 2018), p. 1.
When Is a Spin-Off “Possible”? Eaton 10b-5 Litigation Heads to the Second Circuit, Vol. 27, No. 3, The M&A Tax Report (October 2018), p. 1.
Promoter Penalties and the Full-Payment Rule: FLIP, OPIS, and BLIPS Revisited, Vol. 27, No. 2, The M&A Tax Report (September 2018), p. 1.
First Application of Marinello on Tax Obstruction, Vol. 27, No. 1, The M&A Tax Report (August 2018), p. 6.
Payments Required to Obtain Regulatory Approval Did Not “Facilitate” Merger, Vol. 27, No. 1, The M&A Tax Report (August 2018), p. 4.
Why Are (Some) Publicly Traded Partnerships Electing to Be Taxed as C Corporations?, Vol. 27, No. 1, The M&A Tax Report (August 2018), p. 1.
Bad Investments on the Wrong Side of the Debt-Equity Divide, Vol. 26, No. 12, The M&A Tax Report (July 2018), p. 1.
Marinello Limits Tax Obstruction—Are Klein Conspiracies Next?, Vol. 26, No. 11, The M&A Tax Report (June 2018), p. 1.
S Corporation’s Investment in Family Limited Partnership Lacked Economic Substance, Vol. 26, No. 10, The M&A Tax Report (May 2018), p. 7.
National Security, Foreign Influence, and Code Sec. 1504(a)(2)(A), Vol. 26, No. 10, The M&A Tax Report (May 2018), p. 1.
Continuity of Interest and Valuing Acquirer Stock, Vol. 26, No. 9, The M&A Tax Report (April 2018), p. 6.
New IRS Spin on North-South Transfers and Step Transactions, Vol. 26, No. 9, The M&A Tax Report (April 2018), p. 1.
Buyers Who Boldly Go: Structuring to Avoid Pension Withdrawal Liability Under ERISA, Vol. 26, No. 8, The M&A Tax Report (March 2018), p. 1.
Company’s Tangled M&A Records Convict Shareholder of Obstructing the IRS, Vol. 26, No. 7, The M&A Tax Report (February 2018), p. 6.
IRS Lets Investment Advisor Deduct $275 Million “Support Payment” to Target Shareholders, Vol. 26, No. 7, The M&A Tax Report (February 2018), p. 1.
Transacting with the STARS: Gargantuan Foreign Tax Credits Stumble over Economic Substance, Vol. 26, No. 6, The M&A Tax Report (January 2018), p. 1.
Danielson Strikes Again—Tseytin Revisited, Vol. 26, No. 5, The M&A Tax Report (December 2017), p. 7.
Tell It to Your Analyst? Inversions, Spin-Offs, and Rule 10b-5, Vol. 26, No. 5, The M&A Tax Report (December 2017), p. 1.
Code Sec. 356 and 358 Regulations Are Taxpayer Friendly—But Only if Target Shareholders Use Them, Vol. 26, No. 4, The M&A Tax Report (November 2017), p. 1.
CEO’s Cryptic Email Triggers Sale of Wrong Company, Big Tax Bill; Danielson Bars Relief, Vol. 26, No. 3, The M&A Tax Report (October 2017), p. 1.
Monster McKelvey Estate Tax Case and Litigation Finance, with Robert W. Wood, Vol. 156, No. 10, Tax Notes (September 4, 2017), p. 1299.
The Midco Saga: Is the End Finally In Sight?, Vol. 26, No. 2, The M&A Tax Report (September 2017), p. 1.
M&A Success Fees: Bright Lines, Safe Harbors, and Code Sec. 338(h)(10), Vol. 26, No. 1, The M&A Tax Report (August 2017), p. 1.
Court Holding and Commercially
Reasonable Efforts for Tax Opinions, Vol. 25, No. 12, The M&A Tax Report (July 2017), p. 1.
Exploring Contingent Fee Tax Advice, with Robert W. Wood, Vol. 155, No. 8, Tax Notes (June 12, 2017), p. 1617.
Fallout Continues from AbbVie’s Failed Inversion, Vol. 25, No. 11, The M&A Tax Report (June 2017), p. 5.
Regulatory Freezes and Code Sec. 409A, Vol. 25, No. 10, The M&A Tax Report (May 2017), p. 1.
Breakup Fees, Capitalization and Code Sec. 1234A, Vol. 25, No. 9, The M&A Tax Report (April 2017), p. 1.
Investing in California Real Property — Tax and Withholding, with Robert W. Wood, Vol. 83, No. 10, State Tax Notes (March 6, 2017), p. 853.
Buyer Diligence & Code Sec. 83: All that Glitters…, Vol. 25, No. 8, The M&A Tax Report (March 2017), p. 1.
Taxing Nonresident Investment in California Real Estate, Vol. 25, No. 7, The M&A Tax Report (February 2017), p. 1.
Clarifying Devices and Active Businesses Under Code Sec. 355, Vol. 25, No. 6, The M&A Tax Report (January 2017), p. 1.
Transferee Liability for Shareholders, Even Innocent Ones? (Part 2), Vol. 25, No. 5, The M&A Tax Report (December 2016), p. 5.
F Reorganizations: “Tax Nothings” in a Bubble, Vol. 25, No. 5, The M&A Tax Report (December 2016), p. 1.
Transferee Liability for Shareholders, Even Innocent Ones? (Part 1), Vol. 25, No. 4, The M&A Tax Report (November 2016), p. 4.
CEO Can’t Deduct $44 Million Criminal Forfeiture After All, Vol. 25, No. 3, The M&A Tax Report (October 2016), p. 5.
Tax Inversions, Strategic Benefits and Rule 10b-5, Vol. 25, No. 3, The M&A Tax Report (October 2016), p. 1.
Hook Stock Torpedoes “Should” Opinion, Buyer Scuttles Mega-Merger, Vol. 25, No. 2, The M&A Tax Report (September 2016), p. 1.
Death of Earnings Stripping? Proposed Regs Target Related-Party Debt, Vol. 25, No. 1, The M&A Tax Report (August 2016), p. 1.
Actual Withholding on Code Sec. 305(c) Deemed Distributions, Vol. 24, No. 11, The M&A Tax Report (July 2016), p. 5.
Cardtronics, Terex, Johnson Controls and Pfizer Face Anti-Inversion Regulations, Vol. 24, No. 11, The M&A Tax Report (July 2016), p. 1.
Getting Stock Rights Right Under Code Sec. 305(c), Vol. 24, No. 11, The M&A Tax Report (June 2016), p. 1.
The Nacchio Refund: $17.8 Million Less Than Meets the Eye?, Vol. 151, No. 6, Tax Notes (May 2, 2016), p. 671.
Clawbacks, Code Sec. 1341, and the Item Concept, Vol. 24, No. 9, The M&A Tax Report (April 2016), p. 1.
Spin-Offs Under Code Sec. 355, with Robert W. Wood, Vol. 24, No. 7, The M&A Tax Report (February 2016), p. 1.
SEC Comments on Tax Opinions, with Robert W. Wood, Vol. 24, No. 5, The M&A Tax Report (December 2015), p. 4.
Tax Opinions the SEC Way, with Robert W. Wood, Vol. 149, No. 10, Tax Notes (December 7, 2015), p. 1307.
4 Mass. Practice — Taxation (treatise with Walter G. Van Dorn and Martin S. Allen).
The Scope of Article 9 is Only One-Quarter as Great as is Commonly Supposed, University of
Miami Law Review (March 1993).
Retooling ‘A Bankruptcy Machine That Would Go of Itself’, Boston University Law Review (January
1992).
Developments in the Law — Conflicts of Interest in the Legal Profession, Harvard Law Review (May
1981).
