"Human speech is like a cracked tin kettle, on which we hammer out tunes to make bears
dance when we long to move the stars."
—Flaubert, from Madame Bovary

 

___ T.M. – Federal Taxation of Domestic Insurance Companies, to be published by BNA Tax Management, Inc., Washington, D.C. (anticipated availability - 2010).

T.M. 806 - Immigration and Expatriation Law for the Estate Planner, published by BNA Tax Management, Inc., Washington, D.C.

T.M. 837 2nd – Non-Citizens – Estate, Gift and Generation-Skipping Taxation, published by BNA Tax Management, Inc., Washington, D.C.

[with Glenn Fox] “The Heart of the Matter: The HEART Act and the International Executive” chapter in the treatise The Law of Transnational Business Transactions, (eds. Nanda and Lake), West Group Publishing, New York.

[with Glenn Fox] “The Heart of the Matter: Revised Expatriation Tax Rules under the HEART Act,” Tax Mgt. Estates, Gifts and Trusts Journal, vol. 34, No. 2 (March 2009).

“Pre-Planning Estates for US Investor-Visas,” STEP U.S.A. Journal, 2008 No. 7 (Society of Trust and Estate Practitioners, October 2008).

[with Alan Jahde and Pete Moison] “The Importance of Balance,” STEP U.S.A. Journal, 2007 No. 4 (Society of Trust and Estate Practitioners, September 2007).

[with Glenn Fox and Kevin Mullin] “Some Hot Topics in Inbound Estate Planning,” Tax Mgt. Estates, Gifts and Trusts Journal, vol. 32, No. 3 (May 2007).

“Commentary: The AJCA and the Situs Limitation within the Special Expatriation Estate Tax Regime,” Tax Mgt. Estates, Gifts and Trusts Journal, vol. 31, No. 5 (September 2006), and published on the BNA Tax Management, Inc. website, www.bnatax.com, 2006.

“An Introduction to Immigration Law for the Estate Planner,” Tax Mgt. Memorandum, vol. 46, No. 23 (November 2005).

[with Martin Eveleigh] “Anguilla Seals the Breach: The Levy Exemption in the Insurance Act of 2004,” Tax Mgt. Estates, Gifts and Trusts Journal, vol. 30, No. 4 (July 2005).

“Commentary: Final Regulations Concerning Diversification Requirements for Insurance Contracts,” Tax Mgt. Estates, Gifts and Trusts Journal, vol. 30, No. 3 (May 2005), and published on the BNA Tax Management, Inc. website, www.bnatax.com, 2005.

“Commentary: A Novel FET Issue for NRNCs – Situs of Malpractice Claim, For Faulty FET Advice,” published on the BNA Tax Management, Inc. website, www.bnatax.com, 2005.

“Commentary: New Ruling Allows RIC Double Look-Through for Variable Insurance Contracts,” published on the BNA Tax Management, Inc. website, www.bnatax.com, 2005.

“Commentary: ‘So What?’ Or, Notice 2004-65 Removes Listed Transaction Status for PORCs,” published on the BNA Tax Management, Inc. website, www.bnatax.com, 2004.

“The Reformation of §501(c)(15) by the Pension Funding Equity Act of 2004,” Tax Mgt. Estates, Gifts and Trusts Journal, vol. 29, No. 5 (September 2004).

[with Gregory J. Dean] “Life Insurance as a Financial Institution” chapter in the treatise The Law of Transnational Business Transactions, (eds. Nanda and Lake), West Group Publishing, New York.

“Commentary: Proposed Regulations Concerning Diversification Requirements for Insurance Contracts,” published on the BNA Tax Management, Inc. website, www.bnatax.com, 2003.

“Commentary: New Regulations and PLRs Concerning Offshore Life Insurance,” published on the BNA Tax Management, Inc. website, www.bnatax.com, 2003.

[with Gregory J. Dean] “A Jurisdictional Survey of the Asset Protection Merits of International Life Insurance and Annuities” chapter in the treatise International Life Insurance, 2002, (ed. Whelehan), Chancellor Publishing, London.

“Recent Developments Regarding the Federal Excise Tax on Foreign Insurance Premiums,” Tax Mgt. International Journal, vol. 31, No. 7 (July 2002).

“Barbados Improves its Companies and Insurance Acts: Or, Perseverance Furthers,” Tax Mgt. Estates, Gifts and Trusts Journal, vol. 27, No. 2 (March 2002).

[with Gregory J. Dean] “Augmenting Asset Protection Through an Offshore Life Insurance Policy or Commercial Annuity Contract,” Asset Protection Journal, Spring 2001; re-published as a chapter of the American Bar Association’s Asset Protection Strategies (ed. Bove), 2002.

“Tax Planning and the International Person: Or, There and – Maybe Not – Back Again,” American in Britain (Autumn 2001).

“Islands in the Stream, Revisited: Using the Bahamian External Life Policy or Commercial Annuity Contract in Offshore Investment, Tax and Asset Protection Planning,” Tax Mgt. Estates, Gifts and Trusts Journal, vol. 25, No. 2 (March 2000).

COMMENTS ON PROPOSED TREASURY REGULATIONS

“Comments: Proposed Regulations Concerning Diversification Requirements for Insurance Contracts.” Filed with IRS on October 10, 2003 per REG-163974-02. Revisions to the regulations for section 817(h) of the Code were finalized and the new regulation was enacted on March 1, 2005.

“Comments: The Proposed Regulations for the Federal Excise Tax on Foreign Insurance Premiums.” Filed with IRS on February 21, 2002 per REG-125450-01. Based upon these comments, the regulations were revised to remove the “cascading” excise tax liability that the “insured person” faced under the proposal vis-à-vis the reinsurance premiums paid by an issuing insurer to the foreign reinsurer(s) of such contracts. See Treasury Decision 9024, 67 FR 70845-70846, Nov. 27, 2002.