Winter 2015 Vol. 42, No. 2, Part 3
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1 Winter 2015 Vol. 42, No. 2, Part
2 PART 1 FROM OUR LEADER: TO MOVE DIRECTLY TO AN ARTICLE CLICK ON THE TITLE TABLE OF CONTENTS The Chair's Message Andrius R. Kontrimas, Norton Rose Fulbright SPECIAL RECOGNITIONS, UPCOMING EVENTS, AND SECTION INFORMATION: Leadership Roster ( ) Committee Chairs and Vice Chairs ( ) Calendar ( ) Leadership Academy Graduates ARTICLES: Don t Leave Money on the Table! IRS [Mis]Computation of Interest Robert Probasco, The Probasco Law Firm How to Identify, Prepare for and Succeed in an IRS Eggshell Examination Josh O. Ungerman, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP Tax Collections and the Texas Homestead Michael L. Cook, Cook Brooks Johnson The Perfect Storm Has the Tide Turned Against Offshore Tax Evasion? Jason B. Freeman, Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP Code Section 457A Revisited: Permitted Offshore Deferrals for Investment Fund Managers Chris M. Kang, Haynes and Boone, LLP 1 Texas Tax Lawyer - Winter 2015, Part 3
3 IRS Alphabet Soup: Practical and Precedential Value of AODs, I.R.B.s, TAMs, & Other Guidance Tina R. Green, Capshaw Green, PLLC Nikki L. Laing, Capshaw Green, PLLC The Unified Loss Rules: An Overview Todd Way, Vinson & Elkins LLP Laura Gieseke, Vinson & Elkins LLP A Rose by Any Other Name: Utilizing and Drafting Powers for Trustees, Trustee Advisors, and Trust Protectors Shyla R. Bucker, Sprouse Shrader Smith PLLC Michelle Rosenblatt, Richards Rodriguez & Skeith LLP Cashing In Without Cashing Out: Taking Advantage of Section 1031 Like-Kind Exchanges Kenneth S. Freed, Crady, Jewett & McCulley, LLP Have You Ever Read a Regulation that Could Be Improved? Robert Probasco, The Probasco Law Firm PART 2 PRACTITIONER S CORNER: Nuts and Bolts of Representing Taxpayers Facing Trust Fund Recovery Penalty Assessments Rachael E. Rubenstein, St. Mary s University School of Law Transfer Pricing Litigation Update; Amazon, Medtronic, Other Recent Cases and New lrs Guidance Juan F. Vasquez, Jr., Chamberlain Hrdlicka White Williams & Aughtry Jaime Vasquez, Chamberlain Hrdlicka White Williams & Aughtry Mel E. Myers, Chamberlain Hrdlicka White Williams & Aughtry Current International Tax Issues Adam S. Halpern, Fenwick & West LLP 2 Texas Tax Lawyer - Winter 2015, Part 3
4 PART 3 COMMITTEE ON GOVERNMENT SUBMISSIONS: Comments Pertaining to The Texas Comptroller's Proposed Rule 3.13 Relating to Timely Filing and Payment January 29, 2015 Charolette Noel, Jones Day Ira Lipstet, Dubois, Bryant & Campbell, LLP Comments on Texas Department of Insurance Draft Rules Regarding Professional Employer Organizations and Self-Funded Health Benefit Plans January 7, James Griffin, Jackson Walker LLP Henry Talavera, Polsinelli PC Comments on Proposed Texas Comptroller Rule (Sales & Use Tax Responsibilities and Nexus) December 19, 2014 Charolette Noel, Jones Day Alyson Outenreath, Texas Tech University School of Law Comments on Proposed Texas Comptroller Rules (Aircraft) and (Sale for Resale) December 3, 2014 Charolette Noel, Jones Day Alyson Outenreath, Texas Tech University School of Law The name and cover design of the Texas Tax Lawyer are the property of the State Bar of Texas Tax Section 3 Texas Tax Lawyer - Winter 2015, Part 3
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