Joseph B. Darby III - Previous Publications

 

"Acquisitions in the Valley of the Shadow of Death: How to Purchase - and Resurrect - an Almost-Dead Company," International Finance & Treasury (December 15, 2009)

"Cyprus - Back to the Future: Cyprus, an Ancient Trading Center, has Become a Glitzy New Presence on the International Tax Stage," Practical U.S./International Tax Strategies (November 15, 2009)

"The Forward Triangular Merger: A Not-So-Straight-Forward Transaction," Practical U.S./Domestic Tax Strategies (August 1, 2009)

"Obama Gets Tongue Tied Over Taxes: The Administration Offers Its Long-Awaited International Tax Proposals," Practical U.S./Domestic Tax Strategies (March 31, 2009)

"International Corporate Restructurings: A Multinational Tax Shopper's Guide to Code Section 367(b) and Code Section 1248," Practical U.S./International Tax Strategies (November 30, 2008)

"Q&A with Professor Darby, Tax Writer of the Year," Boston University School of Law Spotlight (October 15, 2008)

"How to Look a Gift Horse in the Mouth," sumnews Summer II (2008)

"The King of Quotes: The Story Behind Yogi Berra's Tangled Logic," Hemisphere Magazine (August 1, 2008)

"The IRS Fixes Subpart F - Sort Of," Practical U.S./International Tax Strategies (July 15, 2008)

"WrestleMania (Exploring the Ongoing Turf Battle Between Taxpayers and the IRS over FLPs)," Private Wealth (June-July 2008)

"International Tax Structuring Using Dutch Cooperatives: Absence of Withholding Tax Makes Structure Attractive as a Holding Company,"  Practical European Tax Strategies (May 1, 2008)

"The Pot Calling the Pot Black: Congress Points a Finger at the Internal Revenue Code (and Itself)," Practical U.S./Domestic Tax Strategies (April 1, 2008)

"Thank God I'm a Country Boy: Why Country Songwriters Now Get Capital Gain Treatment for Their Music," Practical U.S./Domestic Tax Strategies (February 1, 2008)

"IRS Tells All: The Treasury Report to Congress on International Taxation,"  Practical U.S./International Tax Strategies (November 15, 2007)

"Barry Bonds' Home Run #756: There Could be a (Tax) Catch," Practical U.S./Domestic Tax Strategies (July 1, 2007)

"When Tax Planning Rocks: How the Rolling Stones Went Dutch to Cut Taxes - The Untold Story of a 'World Famous Accountant' Named Mick Jagger," Practical U.S./International Tax Strategies (June 30, 2007) and Practical European/Tax Strategies (April 1, 2007)

"Attack (by U.S.) on the 'Killer B': IRS Puts the Sting on Offshore Triangular Reorganizations," Practical U.S./Domestic Tax Strategies (June 15, 2007)

"As the World Churns: Avoiding Tax Planning Disaster by Steering Around Section 197's Anti-Churning Rules: Trap for the Unwary," Practical U.S./Domestic Tax Strategies (June 1, 2007)

"An Intimate Look at Arms' Length: Trying to Grasp the 'Investor Model' in the Proposed Cost-Sharing Regulations," Practical U.S./Domestic Tax Strategies (May 31, 2007)

"Double Irish More Than Doubles the Tax Saving: Hybrid Structure Reduces Irish, U.S. and Worldwide Taxation," Practical U.S./Domestic Tax Strategies (May 15, 2007)

"At Ease: Twelve Rules for Surviving an IRS Audit: In the Battle of Survival, You Need to Think Army" Practical U.S./Domestic Tax Strategies (May 1, 2007)

"The PFIC Storm: How Passive Foreign Investment Company Rules Cause Problems for U.S. Companies with Foreign Subsidiaries," Practical U.S./International Tax Strategies  (April 15, 2007)

"The Tax Man Cometh: The IRS is Back in Business with Aggressive Enforcement of the Tax Laws," Practical U.S./Domestic Tax Strategies  (April 1, 2007)

"What You "C" is What You Get: When Using a C Corporation Makes Sense in a Start-up Business," Practical U.S./Domestic Tax Strategies (March 1, 2007)

"Fantasy Island: The Day the Internal Revenue Code Was Abolished by the DC Circuit Court of Appeals," Practical U.S./Domestic Tax Strategies (January 1, 2007)

"Selling Contracts: A Capital (Gain) Idea," World Trade Executive Practical U.S./Domestic Tax Strategies (December 2006)

"Virtual Mergers - Seeing is Believing," World Trade Executive Practical U.S./International Tax Strategies (December 2006)

"Acquiring IP: Getting Tangible Results from Intangible Assets," World Trade Executive Practical U.S./Domestic Tax Strategies (November 2006)

"Taking Stock - or Assets: Considerations When Structuring an Acquisition of a C Corporation," World Trade Executive Practical U.S./Domestic Tax Strategies (October 2006)

"Giving Tax Credits Where Credit is Due," World Trade Executive Practical U.S./Domestic Tax Strategies (September 2006)

"Where to Park Your Intellectual Property," World Trade Executive Practical U.S./International Tax Strategies (September 30, 2006)

"0 [Zero Extra Tax] Canada - Tax Planning for U.S. - Canada Reorganizations and Mergers," World Trade Executive Practical U.S./International Tax Strategies (September 2006)

"Irish Band Goes Dutch to Cut Taxes: Our Tax Detective Gives the Low Down on U2's Search for the Lowest Possible Tax Rate," World Trade Executive Practical U.S./International Tax Strategies (August 2006)

"Unwinding After a Bad Day: When Undoing the Deal is the Best Tax Solution," World Trade Executive Practical U.S./Domestic Tax Strategies (July 2006)

"Reducing Tax Liability through Commissionaire Agreements: Important Tool in International Tax Planning," World Trade Executive Practical U.S./International Tax Strategies (July 2006)

"Commissionaire Agreements are an Important Tool in International Tax Planning," World Trade Executive Practical European Tax Strategies (July 2006)

"Changes to Subpart F are Favorable to International Business Operations of US Companies," World Trade Executive International Finance & Treasury (July 15, 2006)

"Fixing the U.S. International Tax System: Proposals Motivated by Flight of More Companies for Foreign Shores," World Trade Executive Practical U.S./International Tax Strategies (June 2006)

"Everyone Goes to Zug: Tax Planners Benefit as Swiss Cantons Compete for Lowest Tax Rates," World Trade Executive Practical European Tax Strategies (June 2006)

"Cost Segregation Studies: the Good, the Bad and the Ugly," World Trade Executive Practical U.S./Domestic Tax Strategies (June 2006)

"Eat Your Cake and Have a 338(h)(10) Election Too," World Trade Executive Practical U.S./Domestic Tax Strategies (May 2006)

"Dutch Treat: How the Netherlands has Prospered by Offering Attractive Tax Planning Opportunities," World Trade Executive Practical European Tax Strategies (May 2006)

"The Long Good-Bye," World Trade Executive Practical U.S./International Tax Strategies (April 15, 2006)

"Luck of the Irish: How Shrewd Tax Policies Have Stimulated Economic Growth," World Trade Executive Practical European Tax Strategies (April 2006)

"Re-Syndication Blues, " LIHTC Monthly Report (April 2006)

"Quarterbacking Your Business Using 1031 Exchanges: Like-kind Exchanges Can Avoid Gains," World Trade Executive Practical U.S./Domestic Tax Strategies (April 2006)

"U.S. - Lost and Found: How a Foreign Subsidiary Can Permit an Immediate Deduction for Accounts Receivable," World Trade Executive Practical U.S./International Tax Strategies (March 31, 2006)

"Gertrude Stein Was Wrong: 'A Dollar is a Dollar is a Dollar - Except When it's Not'," World Trade Executive Practical U.S./Domestic Tax Strategies (March 2006)

"Leading the Tax-Examined Life: A Lifestyle Calibrated to Maximize Tax Incentives for Real Estate Ownership," New York Real Estate Journal (March 15, 2006)

"Like Kind and Liking It: Pondering the Neo-Philosophical Question, What Is Real Estate?" New York Real Estate Journal (January 31-February 6, 2006)