Alan S. Lederman

PUBLICATIONS

• "La obtención de información financiera sobre cuentas en sucursales estadounidenses de bancos españoles," Quincena Fiscal Aranzadi, 2024

• "Tax Deferred Reorganization Acquisitions of U.S. Corporations by Foreign Corporations Under Treas. Reg. Sec. 1.367(a)-3(c),” Practicing Law Institute – Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings, 2024
• "Kansas Realty Assessors to Ignore Like-Kind Replacement Price," BNA Tax Management Memorandum, 2024
• “Courts Don’t Allow Sound Engineer to Mix in Revenue Rule Defense,” BNA Tax Management International Journal, 2024
• “Tax Court Gives ‘Great Weight’ to IRS Treaty Interpretation,” BNA Tax Management International Journal, 2024

• "IRS Obtains Data from Spanish Bank for Spanish Tax Authority,” BNA Daily Tax Report and BNA Tax Management International Journal, 2024

• “Trump's NY Businesses Retain Their Federal Tax Classification," BNA Tax Management Memorandum, 2024
• “Reporting Obligations for Foreign Partnerships,” Practicing Law Institute – Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures and Other Strategic Alliances, 2024
• "A Year-End Look At Florida's Capital Investment Tax Credit,” Law360, 2023
• "Corporate Generosity Could Feel Sting of New Minimum Tax Rules," BNA Daily Tax Report, 2023
• "Deducting Fines May Be Fine for GAAP, but Not for Corporate AMT," BNA Tax Management Memorandum, 2023

• "OECD Treatment of Purchased Georgia Film Credits Isn't Peachy," Law360, 2023

• "Proposed 60% Excise Tax Targets Some Foreign Buyers of US Land," BNA Daily Tax Report, 2023
• "Hollywood May Feel a Financial Sting From the Global Minimum Tax," BNA Daily Tax Report, 2023
• "Dwayne Johnson Deal May Benefit From Ford's Corporate Minitax," BNA Daily Tax Report 2023
• “Projected Corporate Minimum Tax Receipts Buffeted by IRS Notice," BNA Daily Tax Report 2023
• “Pillar Two Debt-Discharge Rule Considers Cash-Flow Insolvency," BNA Daily Tax Report 2023
• “Party City Shows Twists of Minimum Tax and Restructuring," BNA Daily Tax Report 2023
• “Will the Cruise Industry Navigate Around the Minimum Tax?," BNA Daily Tax Report 2022
• “Timeshare Sellers May Have a Vacation From Minimum Tax," BNA Daily Tax Report 2022
• “Minimum-Taxed Corporations May Pass By Opportunity Zones,” BNA Daily Tax Report 2022
• "Can Pillar Two Stop a Tax-Free Exit From the Opportunity Zone?," BNA Daily Tax Report and BNA TM Real Estate Journal, 2022
• "Will Pillar Two Block Multinationals' Real Estate Rollovers?," BNA Daily Tax Report, 2022
• "U.S. Taxation and Foreign Expropriation Without U.S. Representation?," BNA Daily Tax Report, 2022
• "U.S. Troop Buildup Calls Polish SOFA to Tax Practitioners’ Attention," BNA Daily Tax Report, 2022
• "Spain's Version of IRS Form 8938 Sanctions Struck Down," BNA Daily Tax Report, 2022
• "Medios contra la evasión fiscal internacional en los Estados Unidos", Jurisdicciones no cooperativas y paraísos fiscales, Capítulo XVI, Tirant Tributario Profesional, 2022
• "Can the Whistle Be Blown Against Accidental Americans?," BNA Daily Tax Report, 2022
• "What You Need to Know About the Proposed Neighborhood Homes Tax Credit: Fla. Homebuilders May Benefit," Daily Business Review, 2022
• "Tesla Tunnel Construction Cost Could Be Sales-Tax Exempt,” BNA Daily Tax Report, 2021
• "U.S. Civil Forfeiture Law Challenged Under Investment Treaty,” BNA Daily Tax Report, 2021
• "The Step Transaction Doctrine Meets Brexit", BNA Daily Tax Report, 2021
• "Infrastructure Plans Build Interest in Low-Interest Government Loans,” BNA Daily Tax Report, 2021
• "When Can an Immigrant and Her Claimed Step-Up in Tax Basis Be Separated at the U.S. Border?’,” BNA Daily Tax Report, 2021
• "Can an Acquired SPAC Avoid Colliding with the ‘Continuity of Business Enterprise’ Doctrine,” BNA Daily Tax Report, 2021
• “Reporting Obligations for Foreign Partnerships,” Practicing Law Institute – Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures and Other Strategic Alliances, 2021
• “Corporate Transparency Act May Obscure Inbound Planning,” BNA Daily Tax Report, 2021
• “Cross-Border Stock Swap Acquisitions in Vogue,” BNA Daily Tax Report, 2020
• “Mideast Peace Dividend May Be Eligible for GILTI Deduction and Foreign Tax Credit,” BNA Daily Tax Report, 2020
• "Can Tangible Property Drive Outside The Opportunity Zone?," BNA Daily Tax Report, 2020
• "Buying Unsold Condominium Inventory In The Opportunity Zone," BNA Daily Tax Report, 2020
• "U.S.-Kenya Trade and Tax Developments," BNA Daily Tax Report, 2020
• "Opportunity Zone Houses Require Substantial Improvement," BNA Daily Tax Report, 2020
• "Eliminating the Inevitability of Farm Debt and Taxes Through Chapter 12 Bankruptcy," BNA Daily Tax Report, 2020
• “Would the IRS Procurement Tax Bring Former WTO-GPA Countries Into Free Trade Agreements?,” BNA Daily Tax Report, 2020
• "US Customs and Tax Rules: South African Reverberations," 78 South African Institute of Tax Professionals TaxTalk 20, 2019
• “New U.S. Tariffs and BEAT Stir Interest in Tax Code Limitation on Related Party Costs,” BNA Daily Tax Report, 2019
• “IRS Relief From Paying High Offshore Taxes Comes With Fine Print,” BNA Daily Tax Report, 2019
• “Atacando cuentas ocultas: la experiencia norteamericana”, Problemas recurrentes de los mercados financieros: Financiación alternativa, gestión de la información y protección del cliente, Capítulo 24, Thomson Reuters Aranzadi, 2019
• “USMCA Reduces NAFTA's Panel Reviews of Tax Cases,” 10 BNA Daily Tax Report 14, 2019
• “General Explanation and Technical Corrections Draft Show QOF Rules Still Uncertain,” 3 BNA Daily Tax Report 14, 2019
• “ABA Section of Taxation Meeting: Cumulative Losses an Open Issue for O-Zone Program,” 162 Tax Notes, January 28, 2019
• "Property Contribution and Basic Issues in Pass-Through Opportunity Funds," 34 BNA Tax Management Real Estate Journal, 2018
• "What Are the Opportunities in Opportunity Funds?," Bloomberg Tax Podcast, 2018
• “Real Estate Gain Deferral and Exclusion through Investments in Qualified Opportunity Funds,” 181 BNA Daily Tax Report 8, 2018
• “Rolling Real Estate Gain into a Qualified Opportunity Fund: Comparison with Section 1031,” 34 BNA Tax Management Real Estate Journal 155, 2018
• “Florida Taxpayers and Businesses May Benefit From Opportunity Zones,” South Florida Daily Business Review, May 11, 2018
• “European Union’s U.S. Tax Treaty Benefits Enhance the European Union’s U.S. Reinsurance Accord Benefits,” 46 BNA Tax Management International Journal, 2017
• "Federal International Procurement Tax Takes Effect," 46 BNA Tax Management International Journal 1, 2017
• "Intermediary Installment Sale Transactions," 32 BNA Tax Management Real Estate Journal 275, 2016
• "Federal International Procurement Tax Debuts," 174 BNA Daily Tax Report J-1, 2016
• “Final Foreign Procurement Regs Clarify Exemptions, Tax Liability,” 2016 Tax Notes Today 160-2, 2016 Worldwide Tax Daily 160-3
• “Proposed Regs. Provide Little Relief to Donees and Heirs of Expatriates,” 124 J. Taxation 60, 2016
• “Don't Include Tax Benefits in Cuba Deals: ABA,” 33 BNA Daily Tax Report G-4, 2016
• “A Hot Topic from Cuba Warming: Taxation of Cuban Expropriation Recoveries,” 45 BNA Tax Management International Journal 12, 2016
• "Procurement Tax Prop. Regs. Streamline Compliance – But Will BRIC Vendors Treaty Shop?," 123 J. Taxation 66, 2015
• “Section 1031 Exchanges: Death of a Related-Party Exchange—Did ‘Butler’ Do It?,” 75 BNA Daily Tax Report J-1, 2015
• “Foreign Procurement Payment Proposed Regs Have Treaty Exclusion,” 2015 Tax Notes Today 77-1, 2015 Worldwide Tax Daily 77-1, 2015
• "Will Foreign Tax Credits Be LOST at Sea?," 43 BNA Tax Management International Journal 752, 2014
• “Are Related Party Acquisitions in Anticipation of Exchange Technically and Theoretically Valid?” 120 J. Taxation 52, 2014
• “Las Nuevas Medidas Fiscales Internacionales Adoptadas en España en Relación con la Evasión Fiscal y la Reducción del Déficit Público,” Thomson Reuters Quincena Fiscal Aranzadi, Febrero 2014
• “The Uncertain Status of the Federal International Procurement Tax,” 119 J. Taxation 127, 2013
• “Spain Looks Abroad to Reduce Deficit at Home,” 42 BNA Tax Management International Journal 467, 2013
• “When Can U.S. Trade Agreements Be Availed of to Compensate for Income Tax Liabilities?” 118 J. Taxation 69, 2013
• “Nazione Non Più Favorita? Despite MFN Clause, IRS Taxes Salaries of Certain Green Card Holders Working for Italian Consulates,” 41 BNA Tax Management International Journal 332, 2012
• “Non-simultaneous Foreign Rollovers May Defer U.S. and Foreign Tax Simultaneously,” 116 J. Taxation 161, 2012
• “Regulations for U.S. Vendor Withholding May Give Clues to Foreign Vendor Withholding,” 41 BNA Tax Management International Journal 80, 2012
• “Beware of Future Withholding On §1031 Exchanges with Governmental Entities,” 189 BNA Daily Tax Report J-1, 2011
• “‘Made in the U.S.A.’ Toll Charge Applies to Sales to U.S. Government of Foreign Items,” 114 J. Taxation 276, 2011
• “The American Assault on Tax Havens – Status Report,” 44 ABA International Lawyer 1141, 2011
• “Coffee? Tea? Section 863? Tax Court Dispenses Double Taxation in International Airspace,” 40 BNA Tax Management International Journal 227, 2011
• “Do Serial Exchangers Get Cash, With Extra Time to Boot, Under New Letter Ruling?” 114 J. Taxation 153, 2011
• “How Powerful Is the Nuclear Reactor Income Tax Credit?” 114 J. Taxation 100, 2011
• “Das Ist Interessant! IRS Exempts U.S. Earned Salaries of Certain U.S. Citizens Living in the United States,” 39 BNA Tax Management International Journal 277, 2010
• “Do AmeriCorps Education Awards Pass the Tax Deferral Tests?” 126 Tax Notes 91, 2010 Tax Notes Today 1-15, 2010
• “Related Party Like-Kind Exchanges: Teruya Brothers and Beyond,” 111 J. Taxation 324, 2009
• “Agribusiness Receives a New Species of Deduction,” 110 J. Taxation 242, 2009
• “Is IRS Immune From Section 911 Iraqi or Afghan Residency Claims?” 121 Tax Notes 1387, 2008 Tax Notes Today 247-36, 2008 World Tax Daily 249-16, 2008
• “IRS Ramps Up Audit Initiative on Withholding From Foreigners,” 109 J. Taxation 350, 2008
• “More on the Uncertain Status of Tax Related Patents,” 109 J. Taxation 379, 2008
• “The Role of State Law in ‘Like-Kind’ Needs to be More Clearly Stated,” 24 BNA Tax Management Real Estate Journal No. 9, 2008
• “Foreign Investment in U.S. Real Estate-FINSA Issues,” 24 BNA Tax Management Real Estate Journal No. 8, 2008
• “Does KSR Obviously Make Tax Patents Obvious?” 66 NYU Tax Institute Chapter 10, 2008
• “IRS Relieves Some of REMIC’s Distress from Relieving Distressed Mortgages,” 24 BNA Tax Management Real Estate Journal, No. 2, 2008
• “Related Party Like-Kind Exchanges,” 115 Tax Notes 467, 2007
• “Controversy Continues for Tax Related Patents,” 106 J. Taxation 255, 2007
• “Active Inducement of Patent Infringement Construed Narrowly,” 106 J. Taxation 255, 2007
• “Proposed Regulations on the Tax Treatment of Private Annuities Would Generally Make them Unattractive,” 106 J. Taxation 175, 2007
• “Tax Related Patents: A Novel Incentive or an Obvious Mistake?” 105 J. Taxation 325, 2006
• “U.S. Sales of Offshore Insurance to Foreigners Streamlined but Issues Remain,” 104 J. Taxation 171, 2006
• “Indofood for Thought: U.K. Court Disapproves Treaty Shopping Trip,” 35 BNA Tax Management International Journal, 2006
• “The Service’s Guidelines for Enjoying the Section 965 Foreign Earnings Tax Holiday,” 103 J. Taxation 208, 2005
• “American Jobs Creation Act Replaces Tax Incentives for Exports with a Domestic Production Tax Break and a One-time Dividends Received Deduction,” 102 J. Taxation 6, 2005
• “Rev. Proc. 2004-51 and Like-Kind Exchanges: The IRS Strikes Back,” 83 CCH Taxes 23, 2005
• “Update on Captive Insurance Companies,” 101 J. Taxation 318, 2004
• “The Service Clarifies the Facts and Circumstances Approach to Captive Insurance Companies,” 100 J. Taxation 168, 2004
• “Build-to-Suit Ruling Breaks New Ground for Taxpayers Seeking Swap Treatment,” 93 J. Taxation 22, 2003
• “The Extraterritorial Income Exclusion Enhances the Tax Benefits Once Sought from FSCs,” 94 J. Taxation 174, 2003
• “International Uses of FASITs Deserve a New Look,” CCH Taxation of Financial Products, 2002
• “Will the New Markets Tax Credit Stimulate Low Income Communities?” AICPA Tax Advisor 390, 689, 2002
• “Eleventh Circuit Declines to Rewrite 20th Century World History,” Florida Bar Journal, 2001
• “Treaty vs. Regulations: Can U.S. Branches Bank on NatWest?” 91 J. Taxation 287, 1999
• “Final Regs. Revamp Withholding on Foreign Persons: Will the New Burdens Backfire?” 88 J. Taxation, 1998
• “New Reporting Rules for Departing U.S. Persons and Property After IRS Guidance and TRA’97,” 87 J. Taxation 149, 1997
• “New Tax Liabilities and Reporting Obligations Imposed on Expatriates,” 85 J. Taxation 325, 1996
• “6662(e) Regs. Barely Loosen Gordian Knot of Compliance,” 7 J. International Taxation 196, 1996
• The NAFTA Guide, Harcourt Brace, 1995
• “Prop. Regs. Implement PFIC Exceptions for Foreign Banks and Securities Dealers,” 83 J. Taxation 38, 1995
• “Conduit Proposed Regulations Are Potent in Effect, but Limited in Scope,” 82 J. Taxation 116, 1995
• “Final Transfer Pricing Regulations Restate Arm’s Length Principles,” 72 Taxes 587, 1994
• “Transfer Pricing Penalty Regs. Create Gordian Know of Compliance,” 5 J. International Taxation 176, 1993
• “CFC Deferral Dwindles, While CFC-PFIC Overlap Increases,” 4 J. International Taxation 436, 1993
• “U.S.-Mexico Tax Treaty Complements NAFTA,” 79 J. Taxation 100, 1993
• “Tax Planning for Debt and Preferred Stock Restructurings Outside of Bankruptcy and Insolvency,” 51 NYU Tax Institute, 1993
• “Temporary Transfer Price Regs. Adopt Best Method Rule,” 72 CCH Taxes 131, 1993
• “Final Branch Regulations Fail to Clear the Thicket of Complexity,” 78 J. Taxation 152, 1993
• “U.S. Tax Residency Rules Broadened in Final Regulations,” 77 J. Taxation 152, 1992
• “The CFC Netting Rule Entangles U.S. Based Multinationals,” 3 J. International Taxation 69, 1992
• “Classification Issues: Limited Partnerships and Limited Liability Companies,” 50 NYU Tax Institute, 1992
• “Proposed Section 482 Regs. Adopt Comparable Profit Interval Requirement,” 70 Taxes 228, 1992
• “Final Regs. Liberalize Caribbean Basin Financing,” 2 J. International Taxation 350, 1992
• “IRS Uses Expanded Conduit Principle to Limit Treaty Shopping,” 76 J. Taxation 170, 1992
• “Low Interest Rate Financing for Jets,” 134 Airfinance Journal 40, 1992
• “Final Regs. Modify Reporting and Recordkeeping Obligations of Foreign Owned Corporations,” 75 J. Taxation 158, 1991
• “Foreign Owned Corporations Face New Recordkeeping Duties,” 74 J. Taxation 186, 1991
• “Private Involvement Can Prejudice Tax Exempt Financing,” 8 HealthSpan 14, 1991
• “Simplified Minimum Participation Prop. Regs. Do Not Resolve All Issues,” 73 J. Taxation 142, 1990
• “Obtaining Tax Advantaged Financing for Investments in the Caribbean Basin,” 72 J. Taxation 104, 1990
• “Foreign Plans Benefiting Some Americans May Be Subject to ERISA,” 8 BNA Tax Management International Journal 476, 1989
• “Miami Device: The Florida Limited Liability Company,” 67 CCH Taxes 339, 1989
• “Low Income Housing and Rehabilitation Syndications,” 47 NYU Tax Institute, 1989
• “Many Options Available to Avoid Excess Passive Investment Income Tax and S Termination,” 69 J. Taxation 4, 1988
• “Condominiums Held for Rental,” 1 NYU Institute on Tax Planning for the Individual 1, 1983
• “Deducting Construction Period Expenses,” 13 AICPA Tax Advisor 480, 524, 1982
• “Temp. Regs Restrict Transfer of Benefits from Mass Transit Financing,” 56 J. Taxation 268, 1982
• “Renovations and Rehabilitations-Tax Aspects,” 39 NYU Tax Institute, 1981
• “Special Tax Benefits of Magazine Publishing to Enhance its Usefulness as a Tax Shelter,” 55 J. Taxation 26, 1981
• “Certified Historic Structures,” BNA Tax Management Portfolio No. 411, 1980
• “Foreign Investment Companies,” BNA Tax Management Portfolio No. 405, 1979
• “The Offshore Finance Subsidiary,” 51 J. Taxation 86, 1979
• “U.S. Taxation of U.S. Portfolio Investments of Controlled Foreign Corporations,” 31 ABA Tax Lawyer 399, 1978
• “Recent IRS Attacks on Captive Foreign Insurance Companies,” 4 International Tax J. 720, 1977

PRESENTATIONS

• "Navigating Digital Taxation and Cross-Border M&A Complexities," February 2025, ABA International Law Section, Singapore
• “Stepping Back into the Step Transaction Doctrine,” ABA Section of Taxation Meeting, May 2024
• "Global Mobility: The Immigration, Employment and Tax Law Implications of Employees Working From Everywhere," Employment Law Alliance Meeting, April 2024
• "Cancellation of Indebtedness Meets OECD Pillar Two and the Inflation Reduction Act of 2022,” ABA Section of Taxation Meeting, May 2023
• "Section 1031 Exchanges,” Florida Real Estate Attorneys’ Fund Meeting, May 2023
• “But What if the Step Transaction Doctrine Applies?,” ABA Section of Taxation Meeting, October 2022
• “1031 and Opportunity Zones Meet the OECD and the Inflation Reduction Act of 2022,” ABA Section of Taxation Meeting, October 2022
• "Combining Opportunity Zone Benefits With Other Incentive Programs," ABA Section of Taxation Meeting, May 2022
• "Proposed Tax Changes in the Build Back Better Bill," ABA Section of Taxation Meeting, February 2022
• "Special Purpose Acquisition Companies," Tulane Tax Institute, November 2021
• "Recent Developments in Like-Kind Exchanges," ABA Section of Taxation Meeting, September 2021
• "Africa's New Era: Investment and Entrepreneurship," ABA Section of International Law Meeting, September 2021
• "Downsizing Income Taxes While Downsizing the Farm,” ABA Section of Taxation Meeting, January 2021
• “Qualified Opportunity Zone Investments,” Family Office Forum December 2020
• “Qualified Opportunity Funds,” Tulane Tax Institute November 2020
• "Structuring Qualified Opportunity Funds," ABA Section of Taxation Meeting, Boca Raton, FL, January 2020
• “Qualified Opportunity Funds Update,” Tulane Tax Institute, New Orleans, LA, November 2019
• “Qualified Opportunity Funds, Section 1031 Exchanges, and Installment Sales,” National Conference on Like-Kind Exchanges, Scottsdale, AZ October 2019
• “Where Do We Stand on Qualified Opportunity Funds?,” ABA Section of Taxation Meeting, San Francisco, CA, September 2019
• "US Customs and Tax Rules: African Reverberations," August 2019 South African Institute of Tax Professionals Tax Indaba, Johannesburg, South Africa
• “Is Now an Opportune Time to Establish Qualified Opportunity Funds,” ABA Section of Taxation Meeting, Washington, D.C., May 2019
• “Where are the Opportunities in Qualified Opportunity Funds,” January 2019 ABA Section of Taxation Meeting, New Orleans, LA
• "U.S. International Tax Changes - Effect on Investments in the U.S. and India," November 2018, Indian National Bar Association, New Delhi, India
• "How U.S. Tax Changes Will Affect U.S.-Asian Transfers of Investment and Technology," October 2018, ABA International Law Section, Seoul, Korea
• “Deferring and Reducing Income Taxes through Qualified Opportunity Funds,” October 2018 ABA Section of Taxation Meeting, Atlanta, GA
• “Atacando Cuentas Ocultas: La Experiencia Norteamericana,” October 2017. Congreso Internacional de Derecho Bancario, Universitat de Valencia, Valencia Spain
• “Current Developments in Section 1031 Like-Kind Exchanges,” October 2017, Florida Bar Tax Section, Miami, FL
• “U.S. Tax Structuring For Non-U.S. Investors into the U.S.,” June 2017, Florida Bar International Law Section - Moscow State Institute of International Relations (MGIMO) Conference, Moscow, Russia
• “Hitting the BRICs: The U.S. International Procurement Tax,” October 2016, ABA International Law Section, Tokyo Japan
• “Investigaciones por el Servicio de Rentas Internas y el Departamento de Justicia de los Estados Unidos,” August 2016 Panama Bankers’ Association Meeting, Panama City, Panama
• “A Hot Topic: Cuban Claims and Section 1033,” ABA Section of Taxation Meeting, Washington, DC, May 2016
• “A Close Examination of the Intermediary Installment Sale Transactions,” January 2016 ABA Section of Taxation Meeting, Los Angeles, CA
• “Rev. Proc. 2015-37: Some Impacts on 'Intentionally defective grantor trusts' in U.S. and Foreign Investor Estate Planning," September 2015 ABA Section of Taxation Meeting, Chicago, IL
• “Use of U.S. Free Trade Agreements and U.S. Investment Treaties in Disputes with Local, State or Federal Governments in the Americas.” June 2015 Globalaw Network Americas Regional Meeting, Montreal, Canada
• “IRS Investigations In Latin America,” August 2015 Panama Bankers Association Convention, Panama
• “Taxation of Franchisors and Franchisees,” May 2015 ABA Section of Taxation Meeting, Washington DC
• “Cross-Border Income Tax Investigations,” March 2015 Florida International Bankers Association Meeting, Miami, FL
• “Regulatory and Policy Focus,” February 2015 Annual Deep Sea Mining Summit, Aberdeen, Scotland
• “‘Over? It’s Not Over Until We Say It’s Over’: Strategies for Extending the 180-day Exchange Deadlines,” September 2014 ABA Section of Taxation Meeting, Denver, CO
• “Rescissions – Where are We Now?,” May 2014 ABA Section of Taxation Meeting, Washington, DC
• “North Central and its Implications for Related Party Exchanges” January 2014 ABA Section of Taxation Meeting, Phoenix, AZ
• “The Very Rare Find: A Section 1031 Collectible Exchange with Definite Answers,” September 2013 ABA Section of Taxation Meeting, San Francisco, CA
• “Hot Topics in Section 1031: Constructive Receipt Issues,” May 2103, ABA Section of Taxation Meeting, Washington, DC
• “Tax Issues Involving Flawed Securitizations,” January 2013, ABA Section of Taxation Meeting, Orlando, FL
• “The Nuclear Reactor Tax Credit, Post-Fukushima,” January 2013, ABA Section of Taxation Meeting, Orlando, FL
• “Issues Surrounding Tax Ownership of U.S. Residential Mortgage Debt,” September 2012, ABA Section of Taxation Meeting, Boston, MA
• “Achieving Simultaneous U.S. and Foreign Tax Deferral on Rollovers of Foreign Assets,” May 2012, ABA Section of Taxation Meeting, Washington, DC
• “Current Developments in Section 1031 and Section 1033 Transactions,” February 2012, ABA Section of Taxation Meeting, Washington, DC
• “Potential Impacts of Fukushima on Nuclear Power Finance,” December 2011, Nuclear Industry Conference, Washington, DC
• “The Nuclear Reactor Income Tax Credit,” October 2011, Nuclear Industry Conference, Charlotte
• “Beware Future Withholding on Section 1031 Exchanges with Governmental Entities,” October 2011, ABA Section of Taxation Meeting, Denver, CO
• “FATCA and Other U.S. Tax Reporting of Panamanian Accounts,” August 2011, Panama Banker’s Association, Panama
• “Section 1031 Developments,” May 2011, ABA Section of Taxation Meeting, Washington, DC
• “The Endangered Species Deduction,” January 2011, ABA Tax Section Meeting, Boca Raton, FL
• “The U.S. Assault on Tax Havens,” December 2010, ABA International Law Section, Paris, France

Professional Associations & Memberships

• ABA Tax Section Committee on Sales Exchanges & Basis, Chairman