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Joseph Septimus photo and interview in the New York Times, "Certainty on Tax, but Just for Two Years," February 9, 2011

Joseph Septimus photo and interview in the Business Section of the New York Times, "Certainty on Tax, but Just for Two Years," by David Cay Johnston, February 9, 2011, concerning estate planning and tax law changes.

Joseph Septimus photo and interview in the New York Times, "Certainty on Tax, but Just for Two Years," February 9, 2011

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Jerald David August Presented at the American Law Institute CLE Video Webcast Event, “Mergers & Acquisitions of S Corporations: How to Structure the Deal"

On Tuesday, December 13, 2011, Jerald David August presented at the American Law Institute CLE Webcast Event, "Mergers & Acquisitions of S Corporations: How to Structure the Deal"

Known for their thorough and practical advice, Planner Jerry August and his co-panelist Steve Looney will walk you through the various methods for selling or purchasing the assets or shares of stock of an S corporation or a closely held regular or C corporation. Among the topics to be highlighted will be the impact of the eligibility rules under Subchapter S in structuring acquisitions involving stock of an S corporation, use of qualified subchapter S subsidiaries, taxable and tax-free acquisitions involving S corporations, section 338 (h)(10) deemed asset sales, tax history portability questions, allocation of income or loss in the year of the acquisition, impact on built in gains tax under Section 1374 and related topics.

 

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Bryan C. Skarlatos quoted in The Wall Street Journal, Tax Report, December 10, 2011, "What's Next for Offshore Accounts?"

Bryan C. Skarlatos quoted in The Wall Street Journal, Tax Report, December 10, 2011, "What's Next for Offshore Accounts?" by Laura Saunders

Bryan C. Skarlatos quoted in The Wall Street Journal, Tax Report, December 10, 2011, "What's Next for Offshore Accounts?"

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Tax Controversies: Audits, Investigations, Trials, 2 Vols.

Robert S. Fink, Author
Kevin M. Flynn, Contributing Author
Sharon L. McCarthy, Contributing Author
Amy Walsh, Contributing Author

Tax Controversies: Audits, Investigations, Trials, 2 Vols. (Lexis/Nexis, 30th Rev. 2011)

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Claude M. Millman quoted in WSJ, November 26, 2011 "Liu Sued Over Prevailing-Wage Hike"

Claude M. Millman quoted in WSJ, November 26, 2011 "Liu Sued Over Prevailing-Wage Hike"

Claude M. Millman quoted in WSJ, November 26, 2011 "Liu Sued Over Prevailing-Wage Hike"

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Bryan C. Skarlatos quoted in Reuters, November 19, 2011, "Ex-UBS banker turned songbird pressures Swiss banks"

Bryan C. Skarlatos quoted in Reuters, November 19, 2011, "Ex-UBS banker turned songbird pressures Swiss banks," by Lynnley Browning and Kevin Gray

Bryan C. Skarlatos quoted in Reuters, November 19, 2011, "Ex-UBS banker turned songbird pressures Swiss banks"

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Bryan C. Skarlatos quoted in The Wall Street Journal, November 9, 2011, " Credit Suisse to Name Names"

Bryan C. Skarlatos quoted in The Wall Street Journal, November 9, 2011, " Credit Suisse to Name Names," by Deborah Ball and Laura Saunders

Bryan C. Skarlatos quoted in The Wall Street Journal, November 9, 2011, " Credit Suisse to Name Names"

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The Required Records Doctrine: The Fifth Amendment Privilege Under Attack

By Christopher M. Ferguson
Journal of Taxation
October Issue, 2011

As part of its wave of investigations into undisclosed overseas bank accounts following its deferred prosecution of UBS AG, the Department of Justice (DOJ) has invoked the required records doctrine, a rarely used exception to the Fifth Amendment, to compel foreign account holders to produce records of their accounts over their Fifth Amendment act-of-production objections. Thus far, with at least one exception, the government largely has been successful in these efforts. Its most significant victory came with the Ninth Circuit's recent, groundbreaking decision in In re: Grand Jury Investigation M.H., 108 AFTR 2d 2011-5880 648 F3d 1067 (CA-9, 2011) ("In re M.H."), in which the court held that foreign bank account owners have no Fifth Amendment right to avoid production of their account records, even if the very act of producing those records would incriminate them.

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Sharon L. McCarthy quoted in The Wall Street Journal, October 26, 2011, "No Clear Quid Pro Quo, No Problem"

Sharon L. McCarthy quoted in The Wall Street Journal, October 26, 2011, "No Clear Quid Pro Quo, No Problem," by Joe Palazzolo

Sharon L. McCarthy quoted in The Wall Street Journal, October 26, 2011, "No Clear Quid Pro Quo, No Problem"

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Sidney Kess quoted in the New York Times, October 18, 2011, "Take Advantage of the Tax Breaks Now, Experts Say"

Sidney Kess quoted in the New York Times, October 18, 2011, "Take Advantage of the Tax Breaks Now, Experts Say," by Jan M. Rosen

Sidney Kess quoted in the New York Times, October 18, 2011, "Take Advantage of the Tax Breaks Now, Experts Say"

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