Table Of Content

INDEX — VOLUME 43 An index to The Tax Executive Professional Journal for Corporate Tax Officers Volume 43 — January-December 1991 SUBJECTS CANADIAN CONSOLIDATED RETURNS ACCOUNTING New Directions in Canadian Tax Policy Judicial Deference, Consolidated Re- BOWMAN, STEPHEN W. turns, and Loss Disallowance: Could Accounting for the Costs of Package September-October 1991, p. 335 LDR Survive a Court Challenge? Designs Amending Section 1502 to Deal Com- ROUSSO, ADA S., and CAPITAL VS. DIVIDENDS prehensively with Single Entity Issues MELBERT E. SCHWARZ SALEM, IRVING March-April 1991, p. 98 Employee Home Transactions by Relo- May-June 1991, p. 167 cation Companies: A Critical Analysis Proposed Loss Disallowance ADMINISTRATIVE ROBERTS, DAVID J. Regulations PROCEDURES July-August 1991, p. 259 WARNER, JAMES C. January-February 1991, p. 17 CAPITAL VS. EXPENSES Accounting for the Costs of Package CONSTITUTIONAL LAW Designs Accounting for the Costs of Package ROUSSO, ADA S., and Designs Update on Attributional Nexus MELBERT E. SCHWARZ ROUSSO, ADA S., and ROSEN, ARTHUR R. March-April 1991, p. 98 MELBERT E. SCHWARZ January-February 1991, p. 46 Advance Pricing Agreements: Practical March-April 1991, p. 98 Beam Resolves Taxpayer Claims under Issues to Consider in Determining Employee Home Transactions by Relo- Davis but Quill Raises New Prospectiv- Whether to Pursue One cation Companies: A Critical Analysis ity Issue PATTON, MICHAEL F. ROBERTS, DAVID J. KOCH, ALBIN C. November-December 1991, p. 392 July-August, 1991, p. 259 September-October 1991, p. 321 IRS Offset Program: A Case Study FRANCIS, LEONARD F. COLLECTION CORPORATE TAX November-December 1991, p. 389 The New Coordinated Examination IRS Offset Program: A Case Study Program FRANCIS, LEONARD F. Judicial Deference, Consolidated Re- MONACO, JOHN J. November-December 1991, p. 389 turns, and Loss Disallowance: Could May-June 1991, p. 161 Open Season on Tax Assessments LDR Survive a Court Challenge? 1990 Act Compliance Provisions May KLEIN, WALTER A., and Amending Section 1502 to Deal Com- ROBERT P. OUELLETTE prehensively with Single Entity Issues Affect Corporate Litigation Strategies July-August 1991, p. 253 SALEM, IRVING SMITH, CARLTON N., and May-June 1991, p. 167 PETER A. GLICKLICH COMPETENT AUTHORITY Proposed Loss Disallowance Regula- March-April 1991, p. 102 tions Resolving Transfer-Pricing Disputes Advance Pricing Agreements: Practical WARNER, JAMES C. Through the Revised Competent Author- Issues to Consider in Determining January-February 1991, p. 17 ity Process Whether to Pursue One REAVEY, EDWIN, and PATTON, MICHAEL F. CORPORATE TAX WILLIAM DUNN November-December 1991, p. 392 MANAGEMENT May-June 1991, p. 177 Resolving Transfer-Pricing Disputes Through the Revised Competent Author- How To Talk So Upper Management AUDITS AND APPEALS ity Process Will Listen (See INTERNAL REVENUE REAVEY, EDWIN, and SHELBY, ANNETTE SERVICE — AUDITS AND WILLIAM DUNN January-February 1991, p. 37 APPEALS) May-June 1991, p. 177 EMPLOYEE BENEFITS Keep the Money at Home: The Illusory CONSUMPTION TAX Promise of Contract Audits Employee Home Transactions by Relo- EVATZ, JAMES N., and New Directions in Canadian Tax Policy cation Companies: A Critical Analysis WAYNE ZAKRZEWSKI BOWMAN, STEPHEN W. ROBERTS, DAVID J. July-August 1991, p. 251 September-October 1991, p. 335 July-August 1991, p. 259 NovEMBER-DECEMBER 1991 INDEX — VOLUME 43 Nonqualified Deferred Compensation Resolving Transfer-Pricing Disputes LITIGATION Plans Backed by Rabbi Trusts Are Gain- Through the Revised Competent Author- ing Popularity ity Process Beam Resolves Taxpayer Claims under KNIGHT, RAY A., and REAVEY, EDWIN, and Davis but Quill Raises New Prospectiv- LEE G. KNIGHT WILLIAM DUNN ity Issue November-December 1991, p. 410 May-June 1991, p. 177 KOCH, ALBIN C. The Tax Treatment of Independent Con- September-October 1991, p. 321 tractors: Where We Are, and Where INTERNATIONAL Judicial Deference, Consolidated Re- We’re Headed turns, and Loss Disallowance: Could HOLLRAH, RUSSELL A. Advance Pricing Agreements: Practical LDR Survive a Court Challenge? September-October 1991, p. 329 Issues to Consider in Determining Amending Section 1502 to Deal Com- ENVIRONMENTAL TAX Whether to Pursue One prehensively with Single Entity Issues PATTON, MICHAEL F. SALEM, IRVING Open Season on Tax Assessments November-December 1991, p. 392 May-June 1991, p. 167 KLEIN, WALTER A., and A Guide to the New Proposed Regula- 1990 Act Compliance Provisions May ROBERT P. OUELLETTE tions under Sections 367(a) and (b) Affect Corporate Litigation Strategies July-August 1991, p. 253 KLEIN, KENNETH, and SMITH, CARLTON N., and DUANE H. PELLERVO PETER A. GLICKLICH INTEREST November-December 1991, p. 397 March-April 1991, p. 102 New Directions in Canadian Tax Policy Update on Attributional Nexus IRS Offset Program: A Case Study BOWMAN, STEPHEN W. ROSEN, ARTHUR R. FRANCIS, LEONARD F. September-October 1991, p. 335 January-February 1991, p. 46 November-December 1991, p. 389 Proposed Section 6038A Regulations: 1990 Act Compliance Provisions May New Recordkeeping, Information Re- MERGERS & ACQUISITIONS Affect Corporate Litigation Strategies porting, Record Production, and Trans- SMITH, CARLTON N., and lation Requirements With Respect to A Guide to the New Proposed Regula- PETER A. GLICKLICH Transactions Between a Foreign-Owned tions under Sections 367(a) and (b) March-April 1991, p. 102 U.S. Corporation and Its Foreign Relat- KLEIN, KENNETH, and ed Parties DUANE H. PELLERVO INTERNAL REVENUE SERVICE - COLE, ROBERT T. November-December 1991, p. 397 AUDITS AND APPEALS January-February 1991, p. 26 Judicial Deference, Consolidated Re- Resolving Transfer-Pricing Disputes turns, and Loss Disallowance: Could Advance Pricing Agreements: Practical Through the Revised Competent Author- LDR Survive a Court Challenge? Issues to Consider in Determining ity Process Amending Section 1502 to Deal Com- Whether to Pursue One REAVEY, EDWIN, and prehensively with Single Entity Issues PATTON, MICHAEL F. WILLIAM DUNN SALEM, IRVING November-December 1991, p. 392 May-June 1991, p. 177 May-June 1991, p. 167 IRS Offset Program: A Case Study Tax Harmony in the European Commu- Proposed Loss Disallowance FRANCIS, LEONARD F. nity Leaves Much to be Desired Regulations November-December 1991, p. 389 KNIGHT, RAY A., and WARNER, JAMES C. The New Coordinated Examination LEE G. KNIGHT January-February 1991, p. 17 Program July-August 1991, p. 257 MONACO, JOHN J. PENALTIES May-June 1991, p. 161 LEGISLATION 1990 Act Compliance Provisions May 1990 Act Compliance Provisions May Affect Corporate Litigation Strategies New Directions in Canadian Tax Policy Affect Corporate Litigation Strategies SMITH, CARLTON N., and BOWMAN, STEPHEN W. SMITH, CARLTON N., and PETER A. GLICKLICH September-October 1991, p. 335 PETER A. GLICKLICH March-April 1991, p. 102 1990 Act Compliance Provisions May March-April 1991, p. 102 Proposed Section 6038A Regulations: Affect Corporate Litigation Strategies Proposed Section 6038A Regulations: New Recordkeeping, Information Re- SMITH, CARLTON N., and New Recordkeeping, Information Re- porting, Record Production, and Trans- PETER A. GLICKLICH porting, Record Production, and Trans- lation Requirements With Respect to March-April 1991, p. 102 lation Requirements With Respect to Transactions Between a Foreign-Owned The Tax Treatment of Independent Con- Transactions Between a Foreign-Owned U.S. Corporation and Its Foreign Relat- tractors: Where We Are, and Where U.S. Corporation and Its Foreign Relat- ed Parties We’re Headed ed Parties COLE, ROBERT T. HOLLRAH, RUSSELL A. COLE, ROBERT T. January-February 1991, p. 26 September-October 1991, p. 329 January-February 1991, p. 26 438 THE Tax EXECUTIVE INDEX — VOLUME 43 PROPERTY TAX STATE & LOCAL TAX A Guide to the New Proposed Regula- tions under Sections 367(a) and (b) Open Season on Tax Assessments Beam Resolves Taxpayer Claims under KLEIN, KENNETH, and KLEIN, WALTER A., and Davis but Quill Raises New Prospectiv- DUANE H. PELLERVO ROBERT P. OUELLETTE ity Issue November-December 1991, p. 397 July-August 1991, p. 253 KOCH, ALBIN C. How To Talk So Upper Management Will Listen September-October 1991, p. 321 QUALITY IMPROVEMENT Keep the Money at Home: The Illusory SHELBY, ANNETTE January-February 1991, p. 37 Promise of Contract Audits IRS Offset Program: A Case Study How To Talk So Upper Management EVATZ, JAMES N., and FRANCIS, LEONARD F. Will Listen WAYNE ZAKRZEWSKI November-December 1991, p. 389 SHELBY, ANNETTE July-August 1991, p. 251 Judicial Deference, Consolidated Re- January-February 1991, p. 37 Open Season on Tax Assessments turns, and Loss Disallowance: Could IRS Offset Program: A Case Study KLEIN, WALTER A., and LDR Survive a Court Challenge? FRANCIS, LEONARD F. ROBERT P. OUELLETTE Amending Section 1502 to Deal Com- November-December 1991, p. 389 July-August 1991, p. 253 prehensively with Single Entity Issues Update on Attributional Nexus SALEM, IRVING RELATED PARTIES ROSEN, ARTHUR R. May-June 1991, p. 167 January-February 1991, p. 46 Keep the Money at Home: The Illusory AIsdsvuaensc e toP riCcoinnsgi Adgerre emienn tDse:t ePrrmaicntiicnagl TAX REFUNDS PromiEsVeA ToZf, C oJntArMaEctS AuNd.i,t sa nd Whether to Pursue One WAYNE ZAKRZEWSKI PATTON, MICHAEL F. IRS Offset Program: A Case Study FRANCIS, LEONARD F. July-August 1991, p. 251 November-December 1991, p. 392 November-December 1991, p. 389 The New Coordinated Examination A Guide to the New Proposed Regula- Program tions under Sections 367(a) and (b) UNIFORM CAPITALIZATION MONACO, JOHN J. KLEIN, KENNETH, and May-June 1991, p. 161 DUANE H. PELLERVO Accounting for the Costs of Package New Directions in Canadian Tax Policy November-December 1991, p. 397 Designs BOWMAN, STEPHEN W. Judicial Deference, Consolidated Re- ROUSSO, ADA S., and September-October 1991, p. 335 turns, and Loss Disallowance: Could MELBERT E. SCHWARZ 1990 Act Compliance Provisions May LDR Survive a Court Challenge? March-April 1991, p. 98 Affect Corporate Litigation Strategies Amending Section 1502 to Deal Com- SMITH, CARLTON N., and prehensively with Single Entity Issues VALUE-ADDED TAX PETER A. GLICKLICH SALEM, IRVING March-April 1991, p. 102 May-June 1991, p. 167 (See CONSUMPTION TAXES) Nonqualified Deferred Compensation Proposed Loss Disallowance Plans Backed by Rabbi Trusts Are Gain- Regulations TITLES ing Popularity WARNER, JAMES C. KNIGHT, RAY A., and January-February 1991, p. 17 Accounting for the Costs of Package LEE G. KNIGHT Proposed Section 6038A Regulations: Designs November-December 1991, p. 410 New Recordkeeping, Information Re- ROUSSO, ADA S., and Open Season on Tax Assessments porting, Record Production, and Trans- MELBERT E. SCHWARZ KLEIN, WALTER A., and lation Requirements With Respect to March-April 1991, p. 98 ROBERT P. OUELLETTE Transactions Between a Foreign-Owned Advance Pricing Agreements: Practical July-August 1991, p. 253 U.S. Corporation and Its Foreign Relat- Issues to Consider in Determining Proposed Loss Disallowance ed Parties Whether to Pursue One Regulations COLE, ROBERT T. PATTON, MICHAEL F. WARNER, JAMES C. January-February 1991, p. 26 November-December 1991, p. 392 January-February 1991, p. 17 Resolving Transfer-Pricing Disputes Beam Resolves Taxpayer Claims under Proposed Section 6038A Regulations: Through the Revised Competent Author- Davis but Quill Raises New Prospectiv- New Recordkeeping, Information Re- ity Process ity Issue porting, Record Production, and Trans- REAVEY, EDWIN, and KOCH, ALBIN C. lation Requirements With Respect to WILLIAM DUNN September-October 1991, p. 321 Transactions Between a Foreign-Owned May-June 1991, p. 177 Employee Home Transactions by Relo- U.S. Corporation and Its Foreign Relat- Update on Attributional Nexus cation Companies: A Critical Analysis ed Parties ROSEN, ARTHUR R. ROBERTS, DAVID J. COLE, ROBERT T. January-February 1991, p. 46 July-August 1991, p. 259 January-February 1991, p. 26 NoOvVEMBER-DECEMBER 1991 INDEX — VOLUME 43 YA Resolving Transfer-Pricing Disputes KLEIN, WALTER A.: Open Season on SALEM, IRVING: Judicial Deference, Through the Revised Competent Author- Tax Assessments (with Robert P. Consolidated Returns, and Loss ity Process Ouellette) Disallowance: Could LDR Survive REAVEY, EDWIN, and July-August 1991, p. 253 a Court Challenge? Amending Sec- WILLIAM DUNN KNIGHT, LEE G.: Nonqualified De- tion 1502 to Deal Comprehensively May-June 1991, p. 177 ferred Compensation Plans Backed with Single Entity Issues Tax Harmony in the European Commu- by Rabbi Trusts Are Gaining May-June 1991, p. 167 nity Leaves Much to be Desired Popularity (with Ray A. Knight) SCHWARZ, MELBERT E.: Accounting KNIGHT, RAY A., and November-December 1991, p. 410 for the Costs of Package Designs LEE G. KNIGHT : Tax Harmony in the (with Ada S. Rousso) July-August 1991, p. 257 European Community Leaves March-April 1991, p. 98 The Tax Treatment of Independent Con- Much to be Desired (with Ray A. SHELBY, ANNETTE: How To Talk So tractors: Where We Are, and Where Knight) Upper Management Will Listen We're Headed July-August 1991, p. 257 January-February 1991, p. 37 HOLLRAH, RUSSELL A. KNIGHT, RAY A: Nonqualified De- SMITH, CARLTON N.: 1990 Act Com- September-October 1991, p. 329 ferred Compensation Plans Backed pliance Provisions May Affect Update on Attributional Nexus by Rabbi Trusts Are Gaining Corporate Litigation Strategies ROSEN, ARTHUR R. Popularity (with Lee G. Knight) (with Peter A. Glicklich) January-February 1991, p. 46 November-December 1991, p. 410 March-April 1991, p. 102 : Tax Harmony in the WARNER, JAMES C.: Proposed Loss AUTHORS European Community Leaves Much Disallowance Regulations to be Desired (with Lee G. Knight) January-February 1991, p. 17 BOWMAN, STEPHEN W.: New Direc- July-August 1991, p. 257 ZAKRZEWSKI, WAYNE: Keep the tions in Canadian Tax Policy KOCH, ALBIN C.: Beam Resolves Tax- Money at Home: The Illusory Prom- September-October 1991, p. 335 payer Claims Under Davis but ise of Contract Audits (with James COLE, ROBERT T.: Proposed Sections Quill Raises New Prospectivity N. Evatz) 6038A Regulations: New Record- Issue July-August 1991, p. 251 keeping, Information Reporting, September-October 1991, p. 321 Record Production, and Transla- MONACO, JOHN J.: The New Coordi- ee tion Requirements With Respect to nated Examination Program Transactions Between a Foreign- May-June 1991, p. 161 THE TAX EXECUTIVE is indexed in Owned U.S. Corporation and Its OUELLETTE, ROBERT P.: Open Sea- the Harvard Law School Library Annu- Foreign Related Parties son on Tax Assessments al Legal Bibliography, Stanford Uni- January-February 1991, p. 26 (with Walter A. Klein) versity Index to Periodical Articles Re- DUNN, WILLIAM: Resolving Trans- July-August 1991, p. 253 lated to Law, The Ten-Year Index to fer-Pricing Disputes Through the PATTON, MICHAEL F.: Advance Pric- Periodical Articles Related to Law Revised Competent Authority Proc- ing Agreements: Practical Is- (Glanville), AICPA Accountants Index, ess (with Edwin Reavey) sues to Consider in Determining Commerce Clearing House Federal Tax May-June 1991, p. 177 Whether to Pursue One Articles, Index to Federal Tax Articles EVATZ, JAMES N.: Keep the Money at November-December 1991, p. 392 (Warren, Gorham & Lamont), and Pub- Home: The Illusory Promise of Con- PELLERVO, DUANE H.: A Guide to lic Affairs Information Service. tract Audits (with Wayne Zakrze- the New Proposed Regulations wski) under Sections 367(a) and (b) July-August 1991, p. 251 (with Kenneth Klein) FRANCIS, LEONARD F.: IRS Offset November-December 1991, p. 397 Program: A Case Study REAVEY, EDWIN: Resolving Trans- November-December 1991, p. 389 fer-Pricing Disputes Through the GLICKLICH, PETER A.: 1990 Act Revised Competent Authority Compliance Provisions May Affect Process (with William Dunn) Corporate Litigation Strategies (with Carlton M. Smith) May-June 1991, p. 177 ROBERTS, DAVID J.: Employee Home March-April 1991, p. 102 HOLLRAH, RUSSELL A.: The Tax Transactions by Relocation Compa- Treatment of Independent Contract- nies: A Critical Analysis ors: Where We Are, and Where July-August 1991, p. 259 ROSEN, ARTHUR R.: Update on Attri- We're Headed September-October 1991, p. 329 butional Nexus KLEIN, KENNETH: A Guide to the January-February 1991, p. 46 New Proposed Regulations under ROUSSO, ADA S.: Accounting for the Sections 367(a) and (b) (with Costs of Package Designs (with Duane H. Pellervo) Melbert E. Schwarz) November-December 1991, p. 397 March-April 1991, p. 98 440