"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
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)