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Publications by Philip R. Hirschfeld

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Featured
Net Operating Losses: A Valuable Asset Worth Preserving
Tax Home v. Abode – Are They the Same for Code §911 Purposes?
Tax Concerns on Outbound I.P. Transfers: Pitfalls & Planning in Light of I.R.S. Defeat in Amazon Case
Implementing the Border Adjustment Tax: Winners & Losers
I.R.S. Rules Subpart F & P.F.I.C. Income Inclusions Are R.E.I.T. Qualifying Income
Insights Vol. 4 No. 1: Updates & Other Tidbits
Looking to the Future: European Efforts Against Tax Evasion Take Center Stage – Where Will It Take Us?
The Resurrection of Code §385: Treasury Department Revises Regulations on Related-Party Debt
The 2016 U.S. Model Income Tax Treaty
§385 Regulations Adopted with Helpful Changes, but Significant Impact Remains
O.E.C.D. Reaction to Research Tax Incentives – Acceptance with a Limitation Blocking Mobility
Uproar Over Proposed §385 Regulations: Will Treasury Delay Adoption?
Crowdfunding: A Popular Way to Invest, but Watch Out for Taxes
Property Contributions to Partnerships with Related Foreign Partners
Proposed Reporting Requirements for Foreign-Owned U.S. Disregarded Entities
Related-Party Debt: Proposed Code §385 Regulations Raise Major New Hurdles
Insights Vol. 3 No. 4: F.A.T.C.A. 24/7
Inversions Under Siege: New Treasury Regulations Issued
Insights Vol. 3 No. 3: F.A.T.C.A. 24/7
2016 Model Treaty – Limitation on Benefits Revisions
Insights Vol. 3 No. 2: Updates & Other Tidbits
Insights Vol. 3 No. 2: F.A.T.C.A. 24/7
Partnership Tax Traps and Recent Guidance
Insights Vol. 3 No. 1: F.A.T.C.A. 24/7
P.A.T.H. Act Leads to Widespread Tax Changes
Insights Vol. 2 No. 10: F.A.T.C.A. 24/7
Congress Enacts Sweeping New Partnership Audit Rules
The Transparent World: Exchange of Information Has Begun & Pacts to Assist Implementation Have Been Signed
President's Legislative Proposals
Insights Vol. 2 No. 8: F.A.T.C.A. 24/7

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Featured
Good News for REITs Investing in Non-US Real Estate

Published in the GGi Insider, No. 88, March 2017 (p. 44).

Foreign Investment in U.S. Real Estate – Think About Taxes Before Investing

Published in Journal of Taxation of Investments, Volume 32, Number 3: Spring 2015. © Civic Research Institute. Authorized Reprint.

Purchasing a Partnership/LLC Interest: Tax Tip #2 – Code Section 754 Election

Published by the American Bar Association in the Real Property Trust & Estate eReport, August 2015.

Purchasing a Partnership/LLC Interest: Tax Tip #1–Requiring Tax Distributions

Published by the American Bar Association in the Real Property Trust & Estate eReport, May 2015.

FATCA Update: Navigating the Electronic Registration Portal

Published by Bloomberg BNA in Tax Management International Journal, 42 TMIJ 687: 2013.

FATCA's Impact on Real Estate Funds

Published in FYI – GGi Real Estate News, No. 04: Summer 2013.

presentations
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