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As time permits, we add links to each of these articles so that you can download them. if you would like a copy of an article for which there is no link. Please note the date of composition - the articles have not been updated and so the older they get, the more you need to handle with care. We don't undertake to update these items.

Permission is given to download these articles but not to republish them by any means or profit from their sale.

Michael Karlin | Jane Peebles

"Strangers in Paradise - and what to do about them", presentation to UBS Securities (September 2008)

"Home Thoughts From Abroad - Foreign Purchases of US Homes", Tax Notes (September 2007).  More detailed discussion of the issues considered in "Home Sweet Home Away From Home"

"Home Sweet Home Away From Home", Outline for ABA Section of Taxation panel presentation, October 2006.  The outline deals with the tax considerations that apply to the purchase by a foreign person of a home in the United States.

"Kissing the Blarney Stone - A Practical Guide to Structuring Partnership Agreements and Limited Liability Company Operating Agreements in Light of the §1446 Regulations", Tax Management Memorandum, May 2006 (co-author)

"Uncle Sam Meets Uncle Scrooge – The Temporary Regulations on Foreign Partner Withholding", Journal of International Taxation, December 2005, part 2 of two-part article (co-author)

"At Long Last . . . The IRS Issues Final Regulations on Foreign Partner Withholding", Journal of International Taxation, October 2005, part 1 of two-part article  (co-author)

American Bar Association Section of Taxation, "Comments on Proposed and Temporary Regulations under Section 1446", October 2005 (co-author and principal editor). These comments dealt with proposed and temporary regulations under section 1446 issued in May 2005 as well as a couple of issues under the final regulations issue at the same time

American Bar Association Section of Taxation, "Comments on Proposed Regulations under Section 1446", January 2004 (Section 1446 deals with withholding on foreign partners in partnerships engaged in a U.S. trade or business - Michael served as co-editor and principal author of the comments); a version of this was also published in Taxation and Regulation of Financial Institutions (May/June 2004)

"U.S. Estate Planning for Nonresident Aliens Who Own Partnership Interests"  Tax Notes, 2003 (editor and co-author)

"Coming to America – When Does Tax Residence Begin?", Journal of International Taxation, 2002

"E-Birth: Starting Up and Getting Real with E-Businesses", Major Tax Planning (Proceedings of the 53rd Annual Institute on Federal Taxation of the USC Law School), published  summer 2001 (co-author)

"Virtual Withholding: Expanding the Observable Universe", Journal of International Taxation, 1999

"On-Line, Off-Base: The Computer Program Final Regulations Miss an Opportunity", Journal of International Taxation, 1999 (co-author)

"Introduction to The Portfolio Interest Exemption" and "Using the Portfolio Interest Exemption", U.S. Taxation of International Operations, Warren Gorham & Lamont, 1988-1999 (looseleaf)  

"Pocket Switching - The Taxation of Electronic Commerce", Major Tax Planning (Proceedings of the 50th Annual Institute on Federal Taxation of the USC Law School), 1998

"Foreign Trusts and Gifts: It’s Getting Warm Offshore", Journal of International Taxation, 1997 (two parts) (editor and co-author)

"Computer Program Prop. Regs. Are a Good But Cautious Start", Journal of International Taxation, 1997

"Overwithholding of Tax on Foreign Partners and Foreign Shareholders - A Regulatory and Legislative Proposal", California Tax Lawyer, 1996 [paper prepared for State Bar of California and LA County Bar Association for presentation to the Internal Revenue Service during annual Washington delegation - also in WordPerfect format; follow-up memorandum (WordPerfect only) to Joni Walser at Treasury Department and Peg O'Connor of IRS Chief Counsel (International)]

"To Protect and Swerve - Asset Protection and the OJ Case", California Law Business, 1996

"IRS proposes comprehensive revision of rules on withholding of payments to foreigners", The In-House Lawyer (London), 1996

"Tax Planning for Doing Business in Mexico", chapter in How to Profit under NAFTA, Business & Legal Reports, Inc. 1995 (looseleaf)  

"Duty Through the Eye of the Withholder", TAXES, 1992 (editor and co-author)

"Diplomatic Silence:  The Secrecy Surrounding Tax Treaty Making Should Be Lifted", Tax Notes International, 1992

"The United States and Mexico Agree to Share Tax Information", International Financial Law Review, 1990

"1986 Act:  Overrides, Conflicts and Interactions with U.S. Income Tax Treaties", Tax Notes, 1987 (co-author)

"Current Planning for Foreign Investors in U.S. Real Estate and Other Direct Investments", Major Tax Planning (Proceedings of the 38th Annual Institute on Federal Taxation of the USC Law School), 1986 (co-author)

"The Unitary System of Taxation in the USA", Law Society's Gazette (London), 1984

"Multinationals and new customs law will have broad impact on intercompany pricing", Journal of Taxation, 1983 (co-author)

"Tax treatment of an individual resident's foreign expatriation losses:  An analysis", Journal of Taxation, 1980 (co-author)

Past author of the annual supplement to the tax chapter in California Condominium and Planned Development Practice, published by California Continuing Education of the Bar; co-founder and editor 1991-1994 of Morgan, Lewis & Bockius LLP quarterly publication International Outlook

Jane Peebles | Michael Karlin

Implications of the Anti-Terrorist Financing Rules for U.S. Charities Making Grants for Use Abroad, Family Foundation Advisor, 2007

"Implications of the Anti-Terrorist Financing Rules for U.S. Charities: Compliance with Executive Order 13224, Planned Giving Design Center", 2006

"Emerging Legal Issues in International Philanthropy", Perspectives on Foundation Management: Innovation and Responsibility at Home and Abroad, John Wiley & Sons, 2002

"Estate Planning Design and Drafting After the EGTRRA", Major Tax Planning (Proceedings of the 52nd Annual Institute on Federal Taxation of the USC Law School), Matthew Bender, 2002

“Hot Topics in Charitable Giving,” Major Tax Planning, Matthew Bender, Proceedings of the 50th Annual Institute on Federal Taxation of the USC Law School, 2000

"Creative Uses of Charitable Lead Trusts", Major Tax Planning (Proceedings of the 49th Annual Institute on Federal Taxation of the USC Law School), Matthew Bender, 1999

"Cross-Border Gifts", Journal of Gift Planning, 2nd quarter, 1999

"Charitable Gifts of Retirement Plan Assets", Planned Giving Design Center, 1999

"Tax Planning for Cross-Border Philanthropy by U.S. Donors", Trusts & Estates Magazine, May 1998

The Handbook of International Philanthropy, Bonus Books, 1998

"Socially Responsible Investment and the Private Trust", Probate & Property Magazine, July/August 1992 (co-author, with Mark Rapaport

"A Primer on U.S. Estate and Gift Taxation of Aliens", Major Tax Planning (Proceedings of the 41st Annual Institute on Federal Taxation of the USC Law School), Matthew Bender, 1991 (co-author, with Michael Karlin)