Table Of Content

1999 THe Tax Executive INDEX Articles by Title As the Big 5 Become Multi-Discip! Practice | Managing an IRS Appeal: Practical Insights and Opportunities Abound for the Tax I ( | Techniques ROSEN, ROBERT ELI HERSKOVITZ, DONALD L., DAVID G. BLATTNER March - April 1999, p. 147 ind JAMES A. DOUGHERTY January - February 1999, p. 36 Buying and Selling a Member of a ¢ dated Group II A Catalogue of the Unique Consoli Return Ru } | Proposed Research Tax Credit Regulations: They Could B. Related Contractual Protections, « Model of the Tax | Worse Provisions for the Acquisition Agr FRANS, MYRON L., and ANDREW T. GARDNER SALEM, IRVING, JIYEON LI January - February 1999, p. 53 and PATRICIA PELLERVO July - August 1999, p. 324 | Recent Private Letter Rulings Prove Partial Liquidatio | Are Alive and Well Canada’s Permanent Establishment ! Threaten U.S BLOOM, GILBERT D. Businesses May - June, 1999, p. 255 LEE, PETER March - April 1999, p. 150 | Recommendations for CEP Process Improvements Involving Specialists Corporate Tax Shelters and Corp: ¢ Management IRS CUSTOMER SATISFACTION TASK FORCE KLEINBARD, EDWARD D. September - October 1999, p. 412 May - June 1999, p. 235 | | The Staffing Challenge of 2000 and Beyond Eleventh-Hour Release of Year-End ! t Netting SANTIAGO, ANTHONY G. and EVE ABRAMS Guidance May - June 1999, p. 252 EVERIDGE, KATHY L. November - December 1999, p. 4 | Tax Department Trends: Organization, Outsourcing, ai | the Use of Consultants Final Section 467 Regulations Pres roblems and ARLINGHAUS, BARRY P. Opportunities January - February 1999, p. 29 LIPTON, RICHARD M. September - October 1999, p. 42& Unclaimed Property Audits: George Orwell Would Be | Proud Interest Netting Encounters Less Than “Global” | SWEENEY, TIMOTHY J. Enthusiasm from the IRS and Trea September - October 1999, p. 436 EVERIDGE, KATHY L. May - June 1999, p. 248 | Whither Corporate Tax Shelters? LIPTON, RICHARD M. Maintaining Machine-Sensible Rec Under Rev. Pro March - April 1999, p. 132 98-25: Comments and Practical Ob tions DICKER, ELI J. January - February 1999, p. 46 NOVEMBER-DECEMBER 1999 1999 THe Tax Executive INDEX Articles by Author ABRAMS, EVE: The Staffing Challenge of 2000 and KLEINBARD, EDWARD D.: Corporate Tax Shelters ar Beyond Corporate Tas Vanagement (with Anthony G. Santiago) I June 1999, p. 235 May - June 1999, p. 252 | ,o I Buy und Selling a Member of a ARLINGHAUS, BARRY P.: Tax Department Trends: nsolidated Group II: A Catalogue of the Unique Organization, Outsourcing, and the Use of Consultants ( lidated Return Rules, the Related Contractual January - February 1999, p. 29 rote nd a Model of the Tax Provisions for the ent (with Irving Salem and Patricia BLATTNER, DAVID G.: Managing an IRS Appeal: Practical Insights and Techniques with Donald J. Herskovitz and James A. Dougherty) January - February 1999, p. 36 | LEE, PETE nada ermanent Establishment Rulk BLOOM, GILBERT D.: Recent Private Letter Rulings Lr’ pril 1999, p. 150 Prove Partial Liquidations Are Alive and Well May - June, 1999, p. 255 PTON, HARD M.: Final Section 467 Regulations ind Opportu nities DICKER, ELI J.: Maintaining Machine-Sensible Records eptember - October 1999, p. 428 Under Rev. Proc. 98-25: Comments and Practical Observations Whither Corporate Tax Shelters? January - February 1999, p. 46 March - April 1999, p. 132 DOUGHERTY, JAMES A.: Managing an IRS Appeal: | PELLERVO, PATRICIA: Buying and Selling a Member Practical Insights and Techniques | a Consolidated Group II: A Catalogue of the Unique with David G. Blattner and Donald L. Herskovitz) O lidated Return Rules, the Related Contractual January - February 1999, p. 36 ectior ind a Model of the Tax Provisions for the ement (with Irving Salem and Jiyeon EVERIDGE, KATHY L.: Eleventh-Hour Release of Year j End Interest Netting Guidance July - August 1999, p. 324 November - December 1999, p. 491 ROSEN, ROBERT ELI: As the Big 5 Become Multi Interest Netting Encounters Less Disciplinary Practices, Opportunities Abound for the Tax Than “Global” Enthusiasm from the IRS and Treasury | Executit May - June 1999, p. 248 rch - April 1999,p . 147 FRANS, MYRON L.: Proposed Research Tax Credit IRVING: Buying and Selling a Member of a Regulations: They Could Be Worse | Consolidated Group II: A Catalogue of the Unique (with Andrew T. Gardner) nsolidated Return Rules, the Related Contractual January - February 1999, p. 53 )tectior nd a Model of the Tax Provisions for the Agreement (with Jiyeon Lee and Patricia GARDNER, ANDREW T:: Proposed Research Tax Credit el Regulations: They Could Be Worse Jul ugust 1999, p. 324 (with Myron L. Frans) January - February 1999, p. 53 SANTIAGO, ANTHONY G.: The Staffing Challenge of 2000 and Bevon ae j HERSKOVITZ, DONALD L.: Managing an IRS Appeal: | (with Eve Abrams Practical Insights and Techniques | May - June 1999, p with David G. Blattner and James A. Dougherty) January - February 1999, p. 36 | SWEENEY, TIMOTHY J.: Unclaimed Property Audits | George Orwell Would Be Proud IRS CUSTOMER SATISFACTION TASK FORCE: September - October 1999, p. 436 Recommendations for CEP Process Improvements Involving Specialists September - October 1999, p. 412 1999 THe Tax Executive INDEX Articles by Subject Administrative Procedures Managing an IRS Appeal: Practical Insights and Techniques Eleventh-Hour Release of Year-Ena rest Nett HERSKOVITZ, DONALD L., DAVID G. BLATTNER Guidance and JAMES A. DOUGHERTY EVERIDGE, KATHY L. January - February 1999, p. 36 November - December 1999, p Recommendations for CEP Process Improvements Interest Netting Encounters Less T! Global” Involving Specialists Enthusiasm from the IRS and Tre« [IRS CUSTOMER SATISFACTION TASK FORCE EVERIDGE, KATHY L. September - October 1999, p. 412 May - June 1999, p. 248 Canadian Maintaining Machine-Sensible Records Und 98-25: Comments and Practical Obs Canada’s Permanent Establishment Rules Threaten U.S DICKER, ELI J. Bu Sinesses January - February 1999, p. 46 LEE, PETER March - April 1999, p. 150 Managing an IRS Appeal: Practical I hts a Techniques Consolidated Returns HERSKOVITZ, DONALD L. (Moderator), DAVID G. BLATTNER, and JAMES A. DOUGHERTY Buying and Selling a Member of a Consolidated Group Il January - February 1999, p. 36 A Catalogue of the Unique Consolidated Return Rules, th Related Contractual Protections, and a Model of the Tax Recent Private Letter Rulings Prove P al Liquidations Provisions for the Acquisition Agreement Are Alive and Well SALEM, IRVING, JIYEON LEE, BLOOM, GILBERT D. and PATRICIA PELLERVO May - June, 1999, p. 255 July - August 1999, p. 324 Recommendations for CEP Process Improvements Corporate Tax Involving Specialists IRS CUSTOMER SATISFACTION rASK FORCE Buying and Selling a Member ofa Consolidated Group II September - October 1999, p. 412 1 Catalogue of ihe Unique Consolidated Return Rules, th Related Contractual Protections, and a Model of the Tax Advanced Technology Provisions for the Acquisition Agreement SALEM, IRVING, JIYEON LEE, Maintaining Machine-Sensible Records | and PATRICIA PELLERVO de * Re l Prov 98-25: Comments and Practical Obse July - August 1999, p. 324 DICKER, ELI J. January - February 1999, p. 46 Corporate Tax Shelters and Corporate Tax Management KLEINBARD, EDWARD D. Audits & Appeals May - June 1999, p. 235 Eleventh-Hour Release of Year-End Interest Nettin Recent Private Letter Rulings Prove Partial Liquidatio? Guidance {re Alive and Well EVERIDGE, KATHY L. BLOOM, GILBERT D. November - December 1999, p. 491 May - June, 1999, p. 255 Interest Netting Encounters Less Than “Global” Whither Corporate Tax Shelters? Enthusiasm frem the IRS and Treasu: LIPTON, RICHARD M. EVERIDGE, KATHY L. March - April 1999, p. 132 May - June 1999, p. 248 Maintaining Machine-Sensible Records Under Ret Proc 98-25: Comments and Practical Observations DICKER, ELI J. January - February 1999, p. 46 NOVEMBER-DECEMBER 1999 1999 Tue Tax Executive INDEX Corporate Tax Management Whither Corporate Tax Shelters? LIPTON, RICHARD M As the Big 5 Become Multi-Disciplinary Practices, Marcl April 1999, p. 132 Opportunities Abound for the Tax Executives ROSEN, ROBERT ELI Mergers, Acquisitions, & Liquidations March - April 1999, p. 147 Bu gand s¢ nga Member of a Consolidated Group Il Corporate Tax Shelters and Corporate Tax Management \ Catalogue of the Unique Consolidated Return Rules, thi KLEINBARD, EDWARD D Related Contractual Protections, and a Model of the Tax May - June 1999, p. 235 Provisions for the Acquisition Agreement SALEM, IRVING, JIYEON LEE, The Staffing Challenge of 2000 and Beyond PATRICIA PELLERVO SANTIAGO, ANTHONY G. and EVE ABRAMS August 1999, p. 324 May - June 1999, p. 252 Recent P ite Letter Rulings Prove Partial Liquidation Tax Department Trends: Organization, Outsourcing, and Are A 1 We the Use of Consultants BLOOM, GILBERTD ARLINGHAUS, BARRY P. M J 1999, p. 255 January - February 1999, p. 29 Non-U.S. Tax Law Interest ( f t Establishment Rules Threaten U.S Eleventh-Hour Releases of Year-End Interest Netting B Guidance LEE ETE EVERIDGE, KATHY L. 4 Ap Q00 D 150 November - December 1999, p 19] Related Parties Intere t Netting Enc unters Less T} an “Global” Enthusiasm from the IRS and Treasury B i) Mi D ofa Consolidated Group I] EVERIDGE, KATHY L 1 ( Un que Consolidated Return Rules, the May - June 1999, p. 248 Re ( Protections, and a Model of the Tax P? Acquisition Agreement International SALEM, IRVING, JIYEON LEE, ind PATRICIA PELLERVO Canada’s Permanent Establishment Rules Threaten U.S Jul August 1999, p. 324 Businesses LEE, PETER Recent P te Letter Rulings Prove Partial Liquidations March - April 1999, p. 150 \ {/ W BLOOM, GILBERT D. Leases May - Ju 1999, p 255 Final Section 467 Regulations Pre sent Problems and Research & Experimentation Expenditures Opportunities LIPTON, RICHARD M. | Research Tax Credit Regulations: They Could Be September - October 1999, p bo x Legislation FRANS, MYRON L GARDNER January - February 1999, p. 53 Corporate Tax Shelters and Corporate Tax Management KLEINBARD, EDWARD D. State & Local May - June 1999, p. 235 ed Property Audits: George Orwell Would Be Whither Corporate Tax Shelters? LIPTON, RICHARD M. SWEENEY, TIMOTHY J. March - April 1999, p. 132 September - October 1999, p. 436 Litigation Tangible Property Corporate Tax Shelters and Corporate Tax Management Final Section 467 Regulations Present Problems and KLEINBARD, EDWARD D. Opportunities May - June 1999, p. 235 LIPTON, RICHARD M. September - October 1999, p. 428 THE Tax EXeEcutivi 1999 THe Tax Executive INDEX TEI Technical Submissions Liaison Meetings Federal Tax Canada Customs and Revenue Age? Excise Tax Iss Confidentiality of Tax Return Information November - December 1999, p. 4 | Letter in Bristol-Myers Barceloneta, Inc. et al. v. Canada Customs and Revenue Agen Income Tax Is United States (D.P.R.) November - December 1999, p. 5 July - August 1999, p. 365 Canadian Department of Finance ~~L Study on Taxpayer Confidentiality by Staffo f November - December 1999, p Joint Committee on Taxation November - December 1999, p. 518 Canadian Department of Finance: I e Tax Issue November - December 1999, p Corporate Tax Shelters Internal Revenue Service (Midstate Testimony on Clinton Administration Budget Proposa March - April 1999, p. 193 before Senate Committee on Finance May - June 1999, p. 258 Internal Revenue Service (New Jers: istrict May - June 1999, p. 286 | Treasury Department White Paper July - August 1999, p. 362 Internal Revenue Service (National O Agenda — January - Februar | Testimony on Treasury Department and Joint Committe: Minutes — March - April 1999 | Proposals before the House Committee on Ways & Mear November - December 1999, p. 494 Internal Revenue Service (Southea January - February 1999, p. 68 Draft Fast Track Mediation Procedure | . September - October 1999, p. 443 U.S. Department of Treasury Agenda — January - February 1999 H.R. 1882: Proposed Amendments to the Regulatory Minutes — March - April 1999, Flexibility Act Concerning Issuance of Tax Regulations November - December 1999, p. 529 Canadian H.R. 2490: IRS Appropriations for FY 2000 1999 Budget Proposal for Offsetting of Interest on September - October 1999, p. 442 Corporate Tax Overpayments and U? ryments May - June 1999, p. 284 , intieer est Ney tting : Increase in Hourly Fee for Advance lh Tax Rulings Rev. Proc. 99-19 September - October 1999, p. 450 May - June 1999, p. 263 Policy Statement P-230 Need for Additional Guidance September - October 1999, p. 452 November - December 1999, p. 534 Report of the Technical Committee on Bu ness Taxation Technical Clarification of Statutory Language Need: January - February 1999, p. 83 July - August 1999, p. 363 Retroactive Legislation — Press Release 99-067 Investment Income of Section 501(c)(6) Organizations Announcing Clarifying Amendments Regarding March - April 1999, p. 177 the Tax Treatment of Resource Expenditures September - October 1999, p. 448 Notice 98-38: Separate Return Limitation Years May - June 1999, p. 275 Transfer Pricing Draft Information Circular (IC) 87-2R May - June 1999, p. 278 NOvVEMBER-DECEMBER 1999 569 Penalty and Interest Study Pre-Study Comments (filed with the staofff th e Joint Ad } ] rier ig Agreements Committee on Taxation and the U.S. Department of Treasury) A? us Brief Fi ed in BNA v. IRS (D.D.C. May - June 1999, p. 267 M aren April 1999, p. 155 Written Statement (filed with the Oversight Subcommittee H.R. 2 377 8: ’ Confidye ntialiwtey of APAs of the House Committee on Ways & Means) Juli ly - August 1999, p. 364 November - December 1999, p. 504 Taxpayer Confidentiality by Staff of Joint ot 1 Performance Measures for IRS Employees in the Comr on Taxation Coordinated Examination Program N ovember - December 1999, p 518 November - December 1999, p. 531 Anno incement9 9 ] Collateral Consequences of U.S. iciati Rev. Proc. 98-25: Record Retention Requirements for | cing Adjustme nts July - August 1999, p. 367 M arch - April 1999, p. 161 Section 41: Proposed Regulations Relating to the lr ¢ tional Complexity and Simplification Computation of the Research Credit and the Definition of Ji August 1999, p. 347 Qualified Research March - April 1999, p. 164 U.K. ( ‘o7n1eSnUu ltatLiLliv e Document on General Anti-Avoidanc« or Direct Taxes Ru f i Section 355(e): Corporate Spinoffs Ja February 1999, p. 79 September - October 1999, p. 444 State and Local Tax Section 6045(f): Information Reporting on Payments of Gross Proceeds to Attorneys Califor t Interest Offset Provision Hunt-Wesson, In November - December 1999, p. 523 Fri Tax Board Significant Problems Encountered By Corporate Ay nicus Le tter to Califor nia Supreme Court Taxpayers March - April, p. 179 January - February 1999, p. 75 September - October 1999, p. 439 Ry Support of a Petition for a Writ of Certiorari July - August 1999, p. 357 United States v. Frederick (Amicus Brief Filed in 7 Cir.) July - August 1999, p. 352 B) Merits in Support of Petitioner November - December 1999, p. 511 THe Tax EXECUTIVE os a ¢z e e h SPMD NADA G O é ‘ ‘ Nee,