Our Publications

A Multinational Survey of the Treatment of Income and Gains of Individuals Who Change Residence

Contributors: Shane M. Brown (Canada); Julia Novak and Laurent Gabaud
(France); Friedhelm Jacob (Germany); Jeremy Cohn (Israel); Eiichiro Nakatani
and Kohei Kajiwara (Japan); James T. O’Neal (Luxembourg); Santiago Chacon
and Alejandro Gordillo Rousse (Mexico); Jean Pierre Viergever (The Netherlands);
Daniel Bader and Ruth Bloch-Riemer (Switzerland); Diana Davidson,
Caroline Kirby, and Caroline Pearce (United Kingdom); Michael J. A. Karlin
(United States).

Article
Michael Karlin
Journal of International Taxation
Journal of International Taxation
March 1, 2017
Requesting Guidance For Treaty Nonresidents

Co-Author:

Liliana Menzie

DLA Piper - San Diego, CA

Article
Michael Karlin
Tax Notes
Tax Notes - September 7, 2015
September 7, 2015
Home Thoughts From Abroad: Foreign Purchases of U.S. Homes

Co-Author:

Stanley C. Ruchelman

Ruchelman Law Firm - New York, NY

Article
Michael Karlin
Tax Notes
Tax Notes - September 3. 2007
September 3, 2007
Brave New World of Estate Planning
Article
Jane Peebles
September 23, 2016
Family Governance - Managing the Challenges of Wealth
Article
Jane Peebles
September 1, 2013
Fundamentals of United States Taxation of Foreign Trusts, Grantors and Beneficiaries
Presentation
Michael Karlin
STEP
The 1st Annual STEP Wyoming Conference
September 1, 2012
Foreign Trusts and Gifts - It's Getting Warm Offshore

Co-Authors:

Dean C. Berry

Ellen K. Harrison

Adina Spiro

Article
Michael Karlin
Journal of International Taxation
Journal of International Taxation
September 1, 1997
At Long Last . . .Final Regulations on Foreign Partner Withholding

Co-Author: 

Alan Appel

Bryan Cave, LLP

Article
Michael Karlin
Journal of International Taxation
Journal of International Taxation
October 5, 2005
Virtual Withholding: Expanding the Observable Universe of Withholding

Co-Author:

Shannon T. Malocha

Article
Michael Karlin
Journal of International Taxation
Journal of International Taxation
October 26, 1999
Home Sweet Home Away From Home

Co-Authors:

Seth J. Entin

Greenberg Traurig, P.A. - Miami, FL

Stanley C. Ruchelman

The Ruchelman Law Firm - New York, NY

Article
Michael Karlin
ABA - Section of Taxation
American Bar Association - Section of Taxation - Committee on US Activities of Foreigners and Tax Treaties
October 20, 2006
Just Giving: Matching Your Resources With Your Values
Article
Jane Peebles
Liberty Hill Foundation
Liberty Hill Foundation
October 20, 2005
A Great Synergy: How Private Foundations Can Beneficially Collaborate With Community Foundations
Article
Jane Peebles
California Community Foundation
California Community Foundation
November 6, 2014
Comments Concerning Proposed Regulations Under Section 1446

Enclosed are comments on proposed regulations under Internal Revenue Code Section 1446.  These comments represent the views of the American Bar Association Section of Taxation. They have not been approved by the Board of Governors or the House of Delegates of the American Bar Association and should not be construed as representing the policy of the American Bar Association. 

Article
Michael Karlin
ABA - Section of Taxation
American Bar Association - Section of Taxation
November 4, 2005
Foreign Investment in U.S. Real Estate
Article
Michael Karlin
Crocker Symposium
November 3, 2014
Foreign Investment in U.S. Real Estate NYU 2011

Co-Author:

Michael Hirschfeld

Dechert LLP

Article
Michael Karlin
New York University
NYU 70th Institute on Federal Taxation - Fall 2011
November 25, 2011
Using the Portfolio Interest Exemption
Article
Michael Karlin
November 24, 1998
Introducing the Portfolio Interest Exemption
Article
Michael Karlin
November 23, 1998
Cybertax - The Impact of the Internet on Interntional Taxation and Vice Versa
Article
Michael Karlin
UCLA Extension 1996 Annual Entertainment Tax and Finance Institute
UCLA Extension 1996 Annual Entertainment Tax and Finance Institute
November 16, 1996
Tax Structuring of Foreign Investment in U.S. Real Estate with a N.Y. Twist

Co-Authors:

Alan I. Appel
Bryan Cave LLP
John P. Barrie
Bryan Cave LLP

Michael Hirschfeld

Dechert LLP 

Article
Michael Karlin
November 15, 2011
Landing Safely in Area 51 - Counseling Aliens About U.S. Taxes
Article
Michael Karlin
Orange County Estate Planning Council
Orange County Estate Planning Council
November 13, 2012
Landing Safely in Area 51 – Counseling Aliens About U.S. Taxes
Presentation
Michael Karlin
Orange County Estate Planning Council
November 13, 2012
Outward Bound - Structuring Considerations for Closely Held Businesses Expanding Abroad
Article
Michael Karlin
STEP Los Angeles
STEP
November 1, 2014
Planning for Foreign Individuals with U.S. Activities Where Tax and Immigration Law Meet (and Sometimes Collide)

Co-Author:

Linda Dodd-Major

Law Offices of Linda Dodd-Major - Washington DC

Article
Michael Karlin
2012 Annual Meeting of the California Tax Bar & California Tax Policy Conference
2012 Annual Meeting of the California Tax Bar & California Tax Policy Conference
November 1, 2012
Planning for Foreign Individuals with U.S. Activities: Where Tax and Immigration Law Meet (and Sometimes Collide)

Presented at the 2012 Annual Meeting of the California Tax Bar and Tax Policy Conference, with co-presenter Linda Dodd-Major

Presentation
Michael Karlin
California Tax Bar and Tax Policy Conference
November 1, 2012
On-Line, Off Base: The Computer Program Final Regulations Miss an Opportunity

Co-Author:

Bradley A. Smith

KPMG LLP, San Diego, CA

Article
Michael Karlin
Journal of International Taxation
Journal of International Taxation
November 1, 1998
Tax Treatment of an Individual Resident's Foreign Expropriation Losses: An Analysis

Co-Author:

Stuart R. Singer

Article
Michael Karlin
Taxation of International Trade
The Journal of Taxation
November 1, 1980
U.S. Estate Planning for Nonresident Aliens Who Own Partnership Interests

Richard Cassell

Bryan Cave - London, UK 

Carlyn McCaffrey

Weil, Gotshal & Manges - New York, NY

William P. Streng

Vinson & Elkins Professor of Law at the University of Houston Law Center and a consultant with Bracewell & Patterson - Houston, Texas 

Article
Michael Karlin
ABA - Section on Taxation
American Bar Association - Section of Taxation - Committee on US Activities of Foreigners and Tax Treaties
May 9, 2003
Cross-border Charitable Giving: International Philanthropy and Tax Laws
Article
Jane Peebles
International Philanthropy and Tax Laws
May 7, 2013
Fundamentals of United States Taxation of Foreign Trusts

Co-Authors:

M. Katharine Davidson

Holland & Knight, LLP - Los Angeles, California

Kent D. Lawson

Burr Pilger Mayer, Inc. - San Francisco, California

Presentation
Michael Karlin
STEP
The 4th Annual STEP Pacific Rim Conference
May 5, 2011
International Grant Making and Fundraising
Article
Jane Peebles
Western Regional Planned Giving Conference
Western Regional Planned Giving Conference
May 29, 2014
Giving In A Low Interest Environment
Article
Jane Peebles
Western Regional Planned Giving Conference
Western Regional Planned Giving Conference
May 28, 2009
Uncle Sam Meets Uncle Scrooge - The Temporary Regulations on Foreign Partner Withholding (Part 2)

Co-Author:

Alan I. Appel

Bryan Cave, LLP - New York, NY

Article
Michael Karlin
IRS Federal Register
IRS Federal Register
May 18, 2005
Kissing the Blarney Stone - A Practical Guide to Structuring Partnership Agreements in Light of the 1446 Regulations

Co-Author:

Alan I. Appel

Bryan Cave, LLP - New York, NY

Article
Michael Karlin
Tax Management Memorandum
Tax Management Memorandum
May 1, 2006
The Failing or Failed Joint Venture - International Tax Considerations
Article
Michael Karlin
5th State Bar International Law Weekend
5th State Bar International Law Weekend
May 1, 1993
Estate Planning in 2013: Mopping Up and Moving On
Article
Jane Peebles
Beverly Hills Estate Planning Council
Beverly Hills Estate Planning Council
March 4, 2013
FBAR RAM YOU: The Meaning of Residence for FBAR Purposes
Article
Michael Karlin
March 3, 2011
International Estate Planning
Article
Michael Karlin and Jane Peebles
USC Gould School of Law
USC Gould School of Law 2009 Tax Institute
March 1, 2009
Charitable Giving: Some Simpler Strategies
Article
Jane Peebles
March 1, 2008
E-Birth: Starting Up And Getting Real With E-Businesses

Co-Author

Janet S. Wong

KPMG LLP

Mountain View, CA.

Article
Michael Karlin
March 1, 2000
Pocket Switching - The Taxation of Electronic Commerce
Article
Michael Karlin
March 1, 1998
Is It Safe? - Dealing with the International Aspects of the United States Tax System
Presentation
Michael Karlin
UBS Sercurities
UBS Sercurities
June 8, 2010
Coming To America - When Does Tax Residence Begin?
Article
Michael Karlin
Journal of International Taxation
Journal of International Taxation
June 26, 2002
Comparison: Donor-Advised Fund - Private Foundation
Article
Jane Peebles
June 16, 2016
Comparison: Donor-Advised Fund - Private Foundation 2014
Article
Jane Peebles
June 1, 2014
A Practical Look at Charitable Lead Trusts
Article
Jane Peebles
June 1, 2012
To Protect and Swerve
Article
Michael Karlin
California Law Business
California Law Business
July 8, 1996
Now You See Them: U.S. Reporting Requirements for Tax Treaty Nonresidents
Article
Michael Karlin
Tax Notes International
Tax Notes International - Volume 67 Number 3
July 16, 2012
Expatriate Games -New Sections 877A and 2801

ABA Section of Taxation Committee on U.S. Activities of Foreigners and Tax Treaties

Article
Michael Karlin
ABA - Section of Taxation
American Bar Association - Section of Taxation
January 9, 2009
Foreign Financial Assets: You Can Run, But You Cannot Hide

Co-Authors:

EDWARD M. ROBBINS, JR
Hochman Salkin Rettig Toscher & Perez, PC, Beverly Hills

ANDY MATTSON
Moss Adams, LLP, Silicon Valley

Article
Michael Karlin
USC Gould School of Law
USC Gould School of Law 2015 Tax Institute
January 25, 2015
Planning for Mobile Executives and Business Owners Relocating to the U.S.

Co-Authors:

Gary Lusk

KPMG, LLP - Atlanta, GA

Grace Fleeman

Senior Technical Reviewer

U.S. IRS, Office of Associate Chief Counsel (Int'l) - Washington, D.C.

Article
Michael Karlin
ABA - Section of Taxation
American Bar Association - Section of Taxation - Committee on US Activities of Foreigners and Tax Treaties
January 21, 2011
When To Remove the Training Wheels And Other Issues In Estate Planning For Productive Children
Article
Jane Peebles
January 18, 2007
Charitable Gifts of Retirement Proceeds
Article
Jane Peebles
January 16, 2008
American Bar Association - Section of Taxation - Comments on Section 1446

Comments concerning proposed regulations relating to the obligation of a partnership to withhold tax under section 1446 on effectively connected taxable income allocable to foreign partners.

Article
Michael Karlin
ABA - Section of Taxation
January 15, 2004
Diplomatic Silence: The Secrecy Shrouding Tax Treaty Making Should Be Lifted
Article
Michael Karlin
Tax Notes International
Tax Analysts - Tax Notes International
January 15, 1992
Cross-Border Grant Making By Private Foundations
Article
Jane Peebles
January 1, 2011
Strangers in Paradise - And What To Do About Them
Article
Michael Karlin
Pomona Valley Estate Planning Council
Pomona Valley Estate Planning Council
February 22, 2011
Living with the Final Partnership Withholding Regulations

Co-Author:

Alan Appel, Esq.

Bryan Cave, LLP - New York, NY

Article
Michael Karlin
Tax Management - International Journal
Tax Management - International Journal
February 13, 2009
Private Foundations, Donor Advised Funds or Both?
Article
Jane Peebles
Advisors in Philanthropy
Advisors in Philanthropy
April 25 2016
International Giving Opportunities
Article
Jane Peebles
April 1, 2016

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