This article highlights the important transactional foreign currency tax issues that U.S. multinationals face and explains why those issues have taken on added importance in an era of volatile exchange rates. It also describes areas in which policymakers could reduce uncertainty regarding foreign currency tax issues by providing targeted guidance.

Omissions From Gross Income And the Chenery Rule

Tax Notes

August 16, 2010

Contingent Consideration and Contingent Liabilities in Acquisitions

Ivins, Phillips & Barker

August 2010

Brand X and Omissions From Gross Income

Tax Notes

February 1, 2010

Proposed Basis Recovery Regulations

BNA Tax Management Memorandum

September 14, 2009

International Tax Proposals Raise Technical Issues

Tax Notes

August 3, 2009

Maximizing the Benefits of Sec. 199 in an Asset Sale

The Tax Advisor

May 1, 2008

Outline of Thoughts on Corporate Distributions

The Tax Magazine

March 2007

The W-2 Wage Limitation On the §199 Deduction: What W-2 wages and Who gets credit for them?

BNATAX Management

January 3, 2007

Musings on Selected Provisions of the Final §199 Regulations Applicable to Corporate Manufacturers of Tangible Property

Tax Management Inc.

September 4, 2006

Federal Bar Association, Section of Taxation Report

Fall 2005

The Domestic Activities Production Deduction: Demystifying the International Tax Aspects

Tax Management International Journal

August 12, 2005

The 199 Domestic Production Activities Deduction: Opportunities, Pitfall, and Ambiguities for Domestic Manufacturers: Part II

Tax Management Memorandum

July 25, 2005

The 199 Domestic Production Activities Deduction: Opportunities, Pitfall, and Ambiguities for Domestic Manufacturers: Part I

Tax Management Memorandum

July 11, 2005

107 Tax Notes 1445 - American Jobs Creation Act of 2004 -- A Selective Analysis

2005 Tax Analysis Tax Notes

June 13, 2005

Tax Bibliographies; Book Reviews, 107 Tax Notes 1445 - American Jobs Creation Act of 2004 -- A Selective Analysis

June 6, 2005

Section 165(g)(3) and Section 332 Memorandum

Ivins, Phillips & Barker

October 8, 2004

87 Tax Notes 1367 - Merging Disregarded Entities

2000 Tax Analysis Tax Notes

June 5, 2000

87 Tax Notes 103 - Mergers & Acquisitions: Questioning Rev. Rul. 96-29's Scope

2000 Tax Analysis Tax Notes

April 3, 2000

79 Tax Notes 1647 - Another Take on Peracchi

1998 Tax Analysts

June 22, 1998

Hybrid Branches Face Stern Test

9 Int'l Tax Review 19

March 1998

Current Issues in International Tax Planning for Motion Picture Production and Distribution

Univ. of Southern California Institute on Federal Taxation

1997

The 6th Edition of B&E: Keeping Pace with the Code, Congress and the Courts

Journal of Taxation

July 1994

More Problems Complicate the Application of 'Substantially All' to Acquisitions

Journal of Taxation

1993

New Guidance Is Needed for the 'Substantially All' Rule as Applied to Acquisitions

Journal of Taxation

1993

IRS Determines Asbestos Removal is Capital Expenditure

Journal of Taxation

October 1992

Improved Development of Complex Tax Legislation

American Journal of Tax Policy

1992

Who Incurs Environmental Clean-Up Costs - And Why - May Determine Deductibility

Journal of Taxation

January 1992

32 Tax Notes 477 - A Revised Roadmap to Section 338

1986 Tax Analysis Tax Notes

August 4, 1986

New Uniform Capitalization and Long-Term Contract Rules

Journal of Taxation

1986

Advantages of New Tax Court Decision Allow Use of LIFO with Completed Contract Method

Journal of Taxation

January 1983

An Analysis of the New Proposed Regulations on Use of Published Indices for Dollar-Value

Journal of Taxation

1981

Insuring that special allocations of partnership income and loss are recognized

Taxation for Lawyers

Making the Most of Special Allocations of Partnership Income and Coping With Risks

Taxation for Lawyers

Employee Benefits

409A Failures: Correcting With and Without the IRS Formal Correction Programs

46th Southern Federal Tax Institute

September 23, 2011

Achieving Success in a Worker Classification Audit

Practical Tax Strategies

November 2010

Taxing Clawbacks

Tax Notes

October 25, 2010

Employers Should Prepare Immediately for PPACA Early Retiree Reinsurance Program

Employee Benefits Insider

May 10, 2010

Notice 2010-38 Clarifies Tax Treatment of Employer-Provided Health Coverage for Adult Children

Employee Benefits Insider

April 28, 2010

Document Failures in the Section 409A-Covered Plan: Correcting With and Without Notice 2010-6

BNA Pension & Benefits Daily

April 12, 2010

Your Large-Employer Health Plan: Timeline for Compliance With Health Reform

April 2010

PBGC Proposed Changes May Trigger Default Under Your Employer's Credit Agreements

Employee Benefits Insider

March 2, 2010

409A Failures: Correcting Outside of the IRS's Formal Correction Programs

Presentation to the DC Bar Tax Section Employee Benefits Committee

February 24, 2010

COBRA Subsidy Extension: What Does This Mean for Employers?

Ivins, Phillips & Barker Employee Benefits Insider

January 2010

409A Document Corrections Under Notice 2010-6

BNA Pension & Benefits Daily

January 8, 2010

Ten Things to Know About In-Service Retirement under PPA

Ivins, Phillips & Barker

October 21, 2009

Seventh Circuit's Contilli Decision Clarifies Requirements for Post-Retirement Actuarial Adjustments

Ivins, Phillips & Barker

September 14, 2009

401(k) Automatic Contribution Arrangement

Ivins, Phillips & Barker

September 9, 2009

409A Failures: Correcting With and Without Notice 2008-113

Tax Notes

August 10, 2009

Summary of Pending Healthcare Legislation

Ivins, Phillips & Barker

August 2009

Fry v. Exelon: How Will the IRS React?

Ivins, Phillips & Barker

July 22, 2009

Benefits Outsourcing Contracts - Negotiate Carefully!

Ivins, Phillips & Barker

July 9, 2009

Accelerated Deductions for Self-Funded Medical IBNR Reimbursements – Even Faster than You May Have Believed

Ivins, Phillips & Barker

June 25, 2009

Second Circuit Victory for PBGC in Oneida Will Make Distress Terminations in Bankruptcy More Expensive

BNA Pension & Benefits Reporter

May 12, 2009

Qualified Retirement Plans

RIA Corporate Controller Manual

2010

Taxing Tenure: An Examination of How the Federal Insurance Contribution Act (FICA) Has Been Applied to Tenure Buyouts

The Tax Lawyer Vol. 62, No. 1

Fall 2008

IRS Backloading Guidance Under Revenue Ruling 2008-7 -- Good and Not-So-Good News for Plan Sponsors

Ivins, Phillips & Barker

February 5, 2008

RSUs and Restricted Stock for Retirement-Eligible Employees -- Tax Surprises under Section 162(m)

Ivins, Phillips & Barker

January 30, 2008

Salary Continuation Arrangements: Still Viable But Proceed With Caution Under Final Code 409A and 415 Regulations

Ivins, Phillips & Barker

April 16, 2007

Pension Protection Act of 2006: Summary for DB Plans

Ivins, Phillips & Barker

September 2006

Vesting of Deferred Compensation: When Words Are More Taxing Than Deeds

Tax Notes

February 6, 2006

Section 409A: Five Points That May Surprise You

Ivins, Phillips & Barker

January 2006

Code Section 409A and the Hidden Deferred Compensation in Executive Employment Agreements

Benefits Law Journal

Fall 2005

EPCRS Update 2006

Ivins, Phillips & Barker

December 2005

Year-End Benefits Checklist 2005

Ivins, Phillips & Barker

November 2005

Cash Bal. Plans & Age Discrimination: The Statute Speaks & (Most) Courts Listen

Benefits Law Journal

Spring 2005

Roth Contributions - Proposed Regulations Issued

Ivins, Phillips & Barker

March 2, 2005

SERPs and Elective Deferral Plans Must Comply With §409A

Pension & Benefits Daily

February 10, 2005

Executive Employment Agreements Must Comply With Section 409A

Daily Tax Report

February 9, 2005

Alert: Change in "Dependent" Definition

Ivins, Phillips & Barker

December 2004

The American Jobs Creation Act of 2004: An Analysis of Selected Provisions

Ivins, Phillips & Barker

November 2004

Limiting 401k Fiduciary Exposure After Enron: Put Your Prose to Work

Benefits Law Journal

Fall 2004

Retroactive Annuity Starting Date: What Do I Have To Do?

Ivins, Phillips & Barker

August 2004

Proposed 411(d)(6) Regulations for Defined Benefit Plans: What To Do Right Now

Ivins, Phillips & Barker

July 2004

Cash Bal. Emergency Preparedness Kit: This Is Not A Test

Benefits Law Journal

Spring 2004

Cash Balance Alert: February 10, 2004

Ivins, Phillips & Barker

January 10, 2004

Berger v. Xerox: Looking for Law in All the Wrong Places

Benefits Law Journal

Fall 2003

Cash Balance Alert: October 30, 2003

Ivins, Phillips & Barker

October 30, 2003

Accruing Benefits for Retired Ees: The Incredible Shrinking Ruling

Benefits Law Journal

Fall 2003

VEBA UBIT Flash

Ivins Phillips & Barker

July 2003

Jobs and Growth Tax Relief Reconciliation Act of 2003

Ivins, Phillips & Barker

June 19, 2003

Cash Bal. Plans & ADEA: IRS Proposes Regs. Under Code section 411(b)(1)(H)

Benefits Law Journal

Spring 2003

What's New in Novation? Discharging Deferred Compensation Obligations Upon Sale of a Business

Benefits Law Journal

Spring 2003

Year-End Benefit Issues 2003

Ivins, Phillips & Barker

2003

Three Rulings in Search of a Theory: Accelerated Deductions for 401k Plan Contributions

Benefits Law Journal

Fall 2002

Double Indemnity: Does Your Plan's Fiduciary Indemnification Clause Protect Your Plan Administrator?

Benefits Law Journal

Fall 2002

Keeping Current with Qualified Plans

Employee Benefits Bulletin

September 10, 2002

Guilt by Association: The ERISA Fiduciary Status of Principals, Agents, Officers, Directors and Other Affiliates

Benefits Law Journal

Summer 2002

Cash Bal. Conversions under ADEA - Reconsidered & Reaffirmed

Benefits Law Journal

Winter 2002

Settlements & Waivers Affecting Pension Benefits Under ERISA

Benefits Law Journal

Fall 2001

The ERISA Common Law and the Limits of Reticulation

Benefits Law Journal

Fall 2001

Flanigan v GE: Last Nail in the Coffin of the Asset "Sale" Bugbear?

Benefits Law Journal

Fall 2001

Plan Expenses: Four Things About the Labor Department's Guidance We Still Don't Understand

Benefits Law Journal

Fall 2001

Consistency Under the Claims Process: ERISA Duty or Regulatory Hobglobin?

Benefits Law Journal

Summer 2001

From the Editors: Scrivener's Error--An Overdue Doctrine for Qualified Plan Corrections

Benefits Law Journal

Spring 2001

Microsoft TAM--Answers Some Questions, Raises Others

Benefits Law Journal

Fall 2000

Benefits in Corporate Asset Sales: Guidance Takes Two Steps Forward, One Step Back

Benefits Law Journal

Fall 2000

Do Cash Bal. Plans Violate the ADEA?

Benefits Law Journal

Summer 2000

Working Overtime to Deal With Evolving Benefits and Pay Practices

Benefits Law Journal

Summer 2000

Is There a Scriveners Error Doctrine

Benefits Law Journal

Spring 2000

Cash Bal. Plans: Are Wear-Away Transitions Legal under the ADEA

Benefits Law Journal

Spring 2000

PensionCabal.com--Ruminations on the Cash Bal. Crisis

Benefits Law Journal

Fall 1999

Perspective--American Stores: IRS Wins Battle But May Have Lost War Against Accelerated Pension Deductions

Benefits Law Journal

Summer 1999

Stand by Your Plan: Disqualification for Failure to Follow the Plan Terms after Shedco

Benefits Law Journal

Summer 1999

Gearing for Battle: Prospects for Health Reform Legislation

Employee Benefits News

April 1, 1999

Nontaxable Benefit Elections: Do They Trigger Taxable Income? More Confusion after Express Oil Change

Benefits Law Journal

Spring 1999

The Ghost in the Machine: Does the All-Events Test Survive in Code Section 404?

Benefits Law Journal

Fall 1998

Whither Guidance?

Benefits Law Journal

Fall 1998

Introduction and Hughes Blues

Benefits Law Journal

Fall 1998

HIPAA's Nondiscrimination Rules: Agencies See Green Light for Regulating Plan Design

Benefits Law Journal

Summer 1997

Overfunded Portion of Foreign Employees' Trust Treated as Grantor Trust

Journal of Taxation

1997

Selected Developments Affecting Qualified Plans: Of Same Desks, Plan Spinoffs and Mergers, and Plan Procedures

New York University Conference on Employee Benefits Taxation

1994

State Withholding from Qualified Plan Distributions

Tax Management Compensation Planning Journal

April 2, 1993

New Final Regulations Offer More Flexibility in Defining Compensation

Journal of Taxation

1993

Cafeteria Plans: Recent Developments and Unresolved Issues

New York University Conference on Employee Benefits Taxation

1991

Final Section 401(k) and (m) Regulations Contain Substantive Changes

Journal of Taxation

1991

5710. Nonqualified Deferred Compensation

Tax Practice Series, The Professional Expediter, BNA

September 17, 1990

Recent Developments Affecting Cafeteria Plans

New York University Conference on Employee Benefits Taxation

1990

Minimum Coverage Prop. Regs. Contain Several New Tests

Journal of Taxation

1989

The Employee Benefit Provisions of the Tax Equity and Fiscal Responsibility Act

ALI-ABA Course Materials Journal

1982

Executive Compensation

Internal Revenue Code Section 409A and the Hidden Deferred Compensation in Executive Employment Agreement

Benefits Law Journal

Summer 2005

Summary of New Law Affecting Nonqualified Deferred Compensation Plans

Ivins, Phillips & Barker

October 22, 2004

Your Nonqualified Deferred Compensation Plans and the New Tax Law: What You Should Do Now - What Can Wait

Ivins, Phillips & Barker

October 22, 2004

Ensuring Deductions for Performance-Based Compensation in Excess of $1 Million

Journal of Taxation

1996

Stock Options Can Ease the Impact of the RRA '93 $1 Million compensation Cap

Journal of Taxation

1994

International Tax

Carter Hood Comments on New Law Governing Foreign Trusts with U.S. Beneficiaries

May 18, 2011

Check-The-Box Reform: (Subpart F)ishing with Dynamite

BNA Tax Management Memorandum

November 23, 2009

International and Corporate Tax Highlights of the American Jobs Creation Act of 2004, Tax Executives Institute

Los Angeles Chapter Meeting

December 2004

Transfer Pricing in the United States and Latin America

BNA Tax Management International Journal

January 11, 2002

What Tax Lawyers Should Know About Trade Law

BNA Tax Management International Journal

October 13, 2000

PFIC Rules: Tax Policy Gone Awry

Tax Notes

1988

International Implications of Internal Revenue Code Section 385 and Related Regulations

New York University Institute on Federal Taxation

1982

Miscellaneous

Implementing a 401(k) Automatic Enrollment Arrangement

September 9, 2009

Restitching the American Marital Quilt: Untangling Marriage from the Nuclear Family

Virginia Law Review

June 2001

Lessons from a Legislative Disaster

Tax Notes

1990

5720. Golden Parachutes

Tax Practice Series, The Professional Expediter, BNA

February 26, 1990

Options Available to a Corporation Acquiring its own stock from estate to deceased shareholder

1980

Tax Accounting

Tax Savings Idea - Change in Treatment of Exchanges of Intangibles For Exchanges that Have Already Taken Place and Been Reported as Taxable

Ivins, Phillips & Barker

November 30, 2009

Final UNICAP Regulations Expand Some Exceptions but Eliminate Others

Journal of Taxation

1994

Final Regs. On Economic Performance Requirement Resolve Most Issues

Journal of Taxation

July 1992

When will Interest be Capitalized Under the New Proposed Regulations?

Journal of Taxation

1991

Long-Term Contract Regulations: Endless Complexity and Planning Opportunities

Journal of Taxation

1986

Premature Accruals and the Relationship Between Accounting Methods and the Penalty Provisions

Univ. of Southern California Law Center, Thirty-Seventh Tax Institute

1985

Tax Controversies

Expedited Opt-Out Needed for OVDI Participants Who Owe No Tax

Tax Notes

January 30, 2012

The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices

Tax Notes

January 16, 2012

Overcoming Appeals' Bad Rap (quotations in article by J. Coder)

Tax Notes

September 2011

DC Circuit: 'The IRS Is Not Special'

Tax Notes

August 30, 2011

Nature Abhors a Splitter: The FTC Splitter and Indirect FTC Rules

Tax Notes

February 14, 2011

Mayo and Chenery: Too Much of a Shift in Rationale?

Tax Notes

October 25, 2010

Gaps in the Seventh Circuit's Reasoning in Lantz

Tax Notes

September 27, 2010

Schedule UTP: Ready or Not, Here It Comes

Tax Management Real Estate Journal

September 1, 2010

Codification of the Economic Substance Doctrine

Business Tax Insider

April 20, 2010

Recovery of Madoff-Related Tax Losses

Ivins, Phillips & Barker

December 2008

Leading Lawyers

The Legal Times

July 18, 2005

Financing Foreign Operations Through Domestic Finance Subsidiaries

Virginia Law Review

1969