Martin Tittle's Curriculum Vitae

Home

Martin B. Tittle

Curriculum Vitae

(Academic CV)

Contact Information:*

Email:
mbt@martintittle.com

Phone:
(202) 344-7592
(734) 846-3864

Fax:
(866) 859-2932

Mail:

P.O. Box 1541
Ann Arbor, MI 48103

*You should be very cautious about the information you reveal in an initial contact or inquiry. I have no duty to keep confidential any information that is communicated to me before you sign an engagement agreement.

Education

University of Michigan Law School, Ann Arbor, Michigan

Juris Doctor Magna Cum Laude, May 2001
Certificate of Merit Award in Estate and Gift Tax, May 2001

University of Michigan, Ann Arbor, Michigan

Bachelor of Music in Piano Performance with High Distinction

Legal Experience

Law Office of Martin B. Tittle, Washington, D.C. and Ann Arbor, Michigan

International Tax Attorney, Winter 2006 - present

Responsibilities: Advise clients on the tax consequences of proposed transactions and work with them to minimize their worldwide effective tax rate; assist clients in their interaction with the U.S. legislative process; contribute articles and chapters to recognized tax publications; speak at professional conferences; create and maintain web site; publish "U.S. International Tax Outlook," a weekly newsletter

PricewaterhouseCoopers LLP, Washington, D.C.

Manager, Fall 2005 - Winter 2006

Responsibilities: Create treaty-based tax strategies; work with team to create spreadsheet model for Internal Revenue Code Section 965; advise client-contact personnel on complex transactional issues

Hantz Group, Inc., Southfield, Michigan

Assistant General Counsel, Spring 2004 - Spring 2005

Responsibilities: Draft and review contracts; establish intellectual property department; create patentable business methods; produce educational materials for internal use; speak at company conferences

Reuven S. Avi-Yonah, Irwin I. Cohn Professor of Law, University of Michigan Law School, Ann Arbor, Michigan

International Tax Consultant, Fall 2002 – Summer 2004

Responsibilities: Analyze issues regarding pending client transactions; draft/co-author scholarly articles for publication in subject areas such as value-added taxes and foreign direct investment in Latin America

Michigan Court of Appeals, Lansing, Michigan

Research Attorney, Fall 2001 – Fall 2002

Responsibilities: Analyze pending appeals; write bench memoranda and draft proposed opinions; mentor student intern

Publications

Books

Planning for Outbound Transfers Under the Section 367(a) and 367(b) Regulations, Including Expatriations, Practicing Law Institute Tax Strategies Course Handbook (October 2008) (with Bobbe Hirsh and Alan S. Lederman)
The Integrated 2006 United States Model Income Tax Treaty, Vandeplas Publishing (February 2008; rev. ed. August 2008) (with Reuven Avi-Yonah)
Permanent Establishment in the United States -- A View Through Article V of the U.S.-Canada Tax Treaty, Vandeplas Publishing (October 2007)
Planning for Outbound Transfers Under the Section 367(a) and 367(b) Regulations, Including Expatriations, Practicing Law Institute Tax Strategies Course Handbook (October 2007) (with Bobbe Hirsh and Alan S. Lederman)

Articles

The Creditability of Mexico's New Flat Tax (with Reuven S. Avi-Yonah) (forthcoming)
A Unified Approach to Permanent Establishment by Agent in the U.S., 48 Tax Notes International 597 (Nov. 5, 2007), 2007 Worldwide Tax Daily 216-10 (Nov. 7, 2007)
The New United States Model Income Tax Convention, IBFD Bulletin for International Taxation, June 2007 (with Reuven S. Avi-Yonah)
Achieving a Territorial Result Without Switching to a Territorial System, 43 Tax Notes International 41 (July 3, 2006), 2006 Worldwide Tax Daily 128-6 (July 5, 2006)
- Leif Mutén, FTC for VAT? A Bizarre Idea, 43 Tax Notes International 303 (July 24, 2006), 2006 Worldwide Tax Daily 144-6 (July 27, 2006)
- Martin B. Tittle, Federal VAT Could Be Harmful for U.S. Retirees, 43 Tax Notes International 419 (July 31, 2006), 2006 Worldwide Tax Daily 149-8 (Aug. 3, 2006)
Comments on proposed changes to Treas. Reg. sec. 1.367(a)-3 in REG-125628-01, (July 18, 2005)
U.S. ETI Repeal and Transition Relief, 32 Tax Notes International 43, 2003 Worldwide Tax Daily 193-16 (Oct. 6, 2003), cited in
- Kristin M. Byrd, "Comment [-] Can We Provide a Level Playing Field for U.S. Corporations and Increase U.S. Jobs While Repealing the Extraterritorial Income [Exclusion] Act?" 5 Houston Bus. and Tax L.J. 341, 346 n.29 (2005)
U.S. Foreign Tax Creditability for VAT: Another Arrow in the ETI/E-VAT Quiver, 30 Tax Notes International 809 (May 26, 2003), 2003 Worldwide Tax Daily 101-16 (May 27, 2003), cited in
- Reuven S. Avi-Yonah, "A Creditable VAT?" 114 Tax Notes 793 (Feb. 19, 2007), 45 Tax Notes International 965 (Mar. 12, 2007), 2007 Worldwide Tax Daily 51-12 (Mar. 15, 2007)
- Richard L. Reinhold, "Some Things that Multilateral Tax Treaties Might Usefully Do," 57 The Tax Lawyer 661, 690 n.149 (Spring 2004)
- Robert J. Peroni, J. Clifton Fleming, Jr., and Stephen E. Shay, "Reform and Simplification of the U.S. Foreign Tax Credit Rules," 31 Tax Notes Int'l 1177, 1203 nn.224, 227 (Sept. 29, 2003); 2003 Worldwide Tax Daily 188-14 (Sept. 29, 2003)
The FSC/ETI Controversy (2003) (background paper on the WTO decisions)
Foreign Direct Investment in Latin America: Overview and Current Status, (original English version) (partial translation into Spanish available on 4th web page of this link - click on "4" at bottom of opening page) Inter-American Development Bank (2002) (with Reuven S. Avi-Yonah), cited in
- Reuven S. Avi-Yonah, "A Creditable VAT?" 114 Tax Notes 793 (Feb. 19, 2007), 45 Tax Notes International 965 (Mar. 12, 2007), 2007 Worldwide Tax Daily 51-12 (Mar. 15, 2007)
- Allison D. Christians, "Tax Treaties for Investment and Aid to Sub-Saharan Africa: A Case Study," 71 Brooklyn L. Rev. 639 (2005)
- Avi Nov, "Tax Incentives for Foreign Direct Investment: The Drawbacks," 38 Tax Notes International 263 (Apr. 18, 2005), 2005 Worldwide Tax Daily 75-10 (Apr. 20, 2005)
- Peter D. Byrne, "Regímenes Tributarios Especiales en la Región Mercosur: Implicancias de Políticas Tributarias y de Comercio para la Integración Regional," Inter-American Development Bank (2003)

Congressional Statements and Minor Commentary

Three Problems Associated with Territorial Taxation, 50 Tax Notes International 1103 (June 30, 2008)
Comments on U.S.-Canada Fifth Protocol and OECD Services Draft, U.S. International Tax Outlook (Feb. 7, 2008), 2008 Worldwide Tax Daily 45-9 (Mar. 5, 2008)
International Tax Reform: Response to Sheppard, 117 Tax Notes 1175 (Dec. 17, 2007), 2007 Tax Notes Today 243-38 (Dec. 18, 2007), 48 Tax Notes International 1261 (Dec. 24, 2007), 2007 Worldwide Tax Daily 248-15 (Dec. 27, 2007)
U.S. International Tax Outlook (weekly newsletter beginning Sept. 4, 2007) (click here for sample issue)
A Projection of the Maximum Revenue Loss from Foreign Tax Credit for Value-Added Taxes, 45 Tax Notes International 969 (March 12, 2007), 2007 Worldwide Tax Daily 51-11 (Mar. 15, 2007), cited in
- Reuven S. Avi-Yonah, "A Creditable VAT?" 114 Tax Notes 793 (Feb. 19, 2007), 45 Tax Notes International 965 (Mar. 12, 2007), 2007 Worldwide Tax Daily 51-12 (Mar. 15, 2007)
U.S. Foreign Tax Credit for VAT, slides to accompany presentation at the January 2007 ABA Tax Section meeting in Hollywood, Florida
Kick-Off for Tax Reform: Tackling the Tax Code: Hearing Before the Committee on Finance, United States Senate, 109th Cong. 325-327 (Aug. 3, 2006) (statement of Martin B. Tittle)
Written Statement, House Ways and Means Committee, Subcommittee on Select Revenue Measures, Hearing on The Impact of International Tax Reform on U.S. Competitiveness, June 22, 2006
Principles vs. Rules: Toward a More Fundamental Formulation of Tax Law, 42 Tax Notes International 769 (May 29, 2006); 2006 Worldwide Tax Daily 104-7 (May 31, 2006)
Toward a Negative Definition of Tax Incentives, 42 Tax Notes International 403 (May 1, 2006); 2006 Worldwide Tax Daily 85-8 (May 3, 2006)
Treatment of Single Limitation Loss and Overall Foreign Loss in a Sec. 965 Context, 40 Tax Notes International 1073 (Dec. 19, 2005); 2005 Woldwide Tax Daily 244-12 (Dec. 21, 2005)
Written Statement, Senate Finance Committee Hearing, October 1, 2003
Written Statement, Senate Finance Committee Hearing, July 15, 2003 (.html) (48K .pdf - typescript) (8.8 MB .pdf - hearing transcript), cited in
- Kristin M. Byrd, "Comment [-] Can We Provide a Level Playing Field for U.S. Corporations and Increase U.S. Jobs While Repealing the Extraterritorial Income [Exclusion] Act?" 5 Houston Bus. and Tax L.J. 341, 350 n.67 (2005)
Questions and Answers on VAT Creditability and ETI Repeal (2003)
Questions and Answers on the Fractional FSC Sanctions (2004)
The European Commission’s Proposed FSC-ETI Sanctions (2003)
Follow-Up Regarding Binding Contract Relief and the Thomas ETI Repeal Bill, 32 Tax Notes International 153 (Oct. 13, 2003), 2003 Worldwide Tax Daily 198-17 (Oct. 14, 2003)
Comment: Argument against Prof. Michael Graetz's Proposal, President's Advisory Panel on Federal Tax Reform (June 10, 2005)
American Exporters Deserve New Tax Credit (2003)
EU Switches from 'Satisfactory Progress' to a Firm Deadline, (2003)
Beneficial Creations of Our Government, Wall Street Journal (Letters), Nov. 4, 2004 (responding to Harold Evans, "From Steam Engine to Search Engine," WSJ, Nov. 3, 2004)
The Tax Cut and New Jobs, The New York Times (Letters), Dec. 21, 2003, sec. 3, at 2

Media Quotes

Roger Russell, "Taxes Know No Borders," Accounting Today, April 19, 2010
Roger Russell, "Administration targets international tax reform," Accounting Today, June 1, 2009
Roger Russell, "International tax: The new hunt for tax havens," Accounting Today, Feb. 23, 2009
Roger Russell, "Who owns America?" Accounting Today, Oct. 6, 2008
Roger Russell, "Cost, complexity clog FIN 48 compliance," Accounting Today, Aug. 18, 2008
Roger Russell, "U.S. tax reformers need to think globally," WebCPA, Aug. 4, 2008
Roger Russell, "Tax haven legislation gaining momentum," WebCPA, April 14, 2008
Roger Russell, "Is the Tax Code unfair to hedge fund investors?" WebCPA, March 31, 2008
Kristen Parillo, "U.S. Senate ratifies German, Belgian treaties," 2007 Worldwide Tax Daily 243-1 (Dec. 18, 2007), 2007 Tax Notes Today 243-5 (Dec. 18, 2007), 117 Tax Notes 1216 (Dec. 24, 2007)
Roger Russell, "TIPRA draws strong reactions," Accounting Today, June 19, 2006 (regarding the repeal of FSC-ETI binding contract grandfathering and the new CFC-to-CFC look-through rule)
Roger Russell, "New regs would change the landscape for intangibles," Accounting Today, Sept. 26, 2005 (regarding transfer pricing)
Roger Russell, "Whose law is it, anyway?" Accounting Today, June 6, 2005 (regarding Pasquantino v. U.S. and the Revenue Rule)
Roger Russell, "IRS board and NRP signal increased compliance focus," Accounting Today, May 2, 2005 (regarding the Son of Boss tax shelter)
Roger Russell, "Maximizing AJCA benefits requires tough calculations," Accounting Today, Nov. 29, 2004
Roger Russell, "For better or worse, Jobs Creation Act of '04 is here," Accounting Today, Nov. 8, 2004
Roger Russell, "American Jobs Creation Act of 2004 headed to White House," WebCPA, Oct. 13, 2004 (regarding the bill's special interest provisions)
Roger Russell, "Repeal of export tax rumbles on," Accounting Today, July 12, 2004 (regarding the difficulties that will face the JOBS bill-AJC Act conferees)
Roger Russell, "House Passes ETI Repeal," WebCPA, June 21, 2004 (regarding passage of H.R. 4520)
Roger Russell, "JOBS sails through Senate," Accounting Today, June 7, 2004 (regarding the JOBS bill and the likely timeline for ETI repeal)
Roger Russell, "U.S. feels backlash for failing to pass JOBS Act," Accounting Today, Apr. 19, 2004 (regarding the delay in repealing ETI)

Conferences

2007 ABA Section of Taxation Midyear Meeting, Hollywood, FL, Jan. 18-20, 2007 (invited speaker)

2006 ABA Section of Taxation May Meeting, Washington, D.C., May 4-6, 2006

Fourth International Tax Institute, Georgetown University Law Center, March 16-17, 2006

Eighteenth Annual Institute on Current Issues in International Taxation, Washington, D.C., December 8-9, 2005

Michigan Bar Association 18th Annual Tax Conference, Plymouth, MI, May 26, 2005

2005 ABA Section of Taxation May Meeting, Washington, D.C., May 19-21, 2005

Sixteenth Annual Institute on Current Issues in International Taxation, Washington, D.C., December 11-12, 2003

International Tax Institute, Fordham University Law School, June 3-4, 2003

Bar Activities

Member, State Bar of Michigan (P57978)

Member, Bar of the District of Columbia Court of Appeals

Member, Bar of the United States District Court for the Northern District of Texas

Member, Bar of the United States District Court for the Eastern District of Michigan

Vice-chair, ABA Report on Proposed Revision of Income Tax Regulations under Sections 358, 367, 884, and 6038B Dealing with Statutory Mergers or Consolidations under Section 368(a)(1)(A) Involving One or More Foreign Corporations, May 2005

Home


Home
		Martin B. Tittle
			Curriculum Vitae


			(Academic CV)
	Contact Information:* Email: mbt@martintittle.com Phone: (202) 344-7592 (734) 846-3864 Fax: (866) 859-2932 Mail: P.O. Box 1541 Ann Arbor, MI 48103 *You should be very cautious about the information you reveal in an initial contact or inquiry. I have no duty to keep confidential any information that is communicated to me before you sign an engagement agreement.		Education University of Michigan Law School, Ann Arbor, Michigan Juris Doctor Magna Cum Laude, May 2001 Certificate of Merit Award in Estate and Gift Tax, May 2001 University of Michigan, Ann Arbor, Michigan Bachelor of Music in Piano Performance with High Distinction Legal Experience Law Office of Martin B. Tittle, Washington, D.C. and Ann Arbor, Michigan International Tax Attorney, Winter 2006 - present Responsibilities: Advise clients on the tax consequences of proposed transactions and work with them to minimize their worldwide effective tax rate; assist clients in their interaction with the U.S. legislative process; contribute articles and chapters to recognized tax publications; speak at professional conferences; create and maintain web site; publish "U.S. International Tax Outlook," a weekly newsletter PricewaterhouseCoopers LLP, Washington, D.C. Manager, Fall 2005 - Winter 2006 Responsibilities: Create treaty-based tax strategies; work with team to create spreadsheet model for Internal Revenue Code Section 965; advise client-contact personnel on complex transactional issues Hantz Group, Inc., Southfield, Michigan Assistant General Counsel, Spring 2004 - Spring 2005 Responsibilities: Draft and review contracts; establish intellectual property department; create patentable business methods; produce educational materials for internal use; speak at company conferences Reuven S. Avi-Yonah, Irwin I. Cohn Professor of Law, University of Michigan Law School, Ann Arbor, Michigan International Tax Consultant, Fall 2002 – Summer 2004 Responsibilities: Analyze issues regarding pending client transactions; draft/co-author scholarly articles for publication in subject areas such as value-added taxes and foreign direct investment in Latin America Michigan Court of Appeals, Lansing, Michigan Research Attorney, Fall 2001 – Fall 2002 Responsibilities: Analyze pending appeals; write bench memoranda and draft proposed opinions; mentor student intern Publications Books Planning for Outbound Transfers Under the Section 367(a) and 367(b) Regulations, Including Expatriations, Practicing Law Institute Tax Strategies Course Handbook (October 2008) (with Bobbe Hirsh and Alan S. Lederman) The Integrated 2006 United States Model Income Tax Treaty, Vandeplas Publishing (February 2008; rev. ed. August 2008) (with Reuven Avi-Yonah) Permanent Establishment in the United States -- A View Through Article V of the U.S.-Canada Tax Treaty, Vandeplas Publishing (October 2007) Planning for Outbound Transfers Under the Section 367(a) and 367(b) Regulations, Including Expatriations, Practicing Law Institute Tax Strategies Course Handbook (October 2007) (with Bobbe Hirsh and Alan S. Lederman) Articles The Creditability of Mexico's New Flat Tax (with Reuven S. Avi-Yonah) (forthcoming) A Unified Approach to Permanent Establishment by Agent in the U.S., 48 Tax Notes International 597 (Nov. 5, 2007), 2007 Worldwide Tax Daily 216-10 (Nov. 7, 2007) The New United States Model Income Tax Convention, IBFD Bulletin for International Taxation, June 2007 (with Reuven S. Avi-Yonah) Achieving a Territorial Result Without Switching to a Territorial System, 43 Tax Notes International 41 (July 3, 2006), 2006 Worldwide Tax Daily 128-6 (July 5, 2006) Leif Mutén, FTC for VAT? A Bizarre Idea, 43 Tax Notes International 303 (July 24, 2006), 2006 Worldwide Tax Daily 144-6 (July 27, 2006) Martin B. Tittle, Federal VAT Could Be Harmful for U.S. Retirees, 43 Tax Notes International 419 (July 31, 2006), 2006 Worldwide Tax Daily 149-8 (Aug. 3, 2006) Comments on proposed changes to Treas. Reg. sec. 1.367(a)-3 in REG-125628-01, (July 18, 2005) U.S. ETI Repeal and Transition Relief, 32 Tax Notes International 43, 2003 Worldwide Tax Daily 193-16 (Oct. 6, 2003), cited in Kristin M. Byrd, "Comment [-] Can We Provide a Level Playing Field for U.S. Corporations and Increase U.S. Jobs While Repealing the Extraterritorial Income [Exclusion] Act?" 5 Houston Bus. and Tax L.J. 341, 346 n.29 (2005) U.S. Foreign Tax Creditability for VAT: Another Arrow in the ETI/E-VAT Quiver, 30 Tax Notes International 809 (May 26, 2003), 2003 Worldwide Tax Daily 101-16 (May 27, 2003), cited in Reuven S. Avi-Yonah, "A Creditable VAT?" 114 Tax Notes 793 (Feb. 19, 2007), 45 Tax Notes International 965 (Mar. 12, 2007), 2007 Worldwide Tax Daily 51-12 (Mar. 15, 2007) Richard L. Reinhold, "Some Things that Multilateral Tax Treaties Might Usefully Do," 57 The Tax Lawyer 661, 690 n.149 (Spring 2004) Robert J. Peroni, J. Clifton Fleming, Jr., and Stephen E. Shay, "Reform and Simplification of the U.S. Foreign Tax Credit Rules," 31 Tax Notes Int'l 1177, 1203 nn.224, 227 (Sept. 29, 2003); 2003 Worldwide Tax Daily 188-14 (Sept. 29, 2003) The FSC/ETI Controversy (2003) (background paper on the WTO decisions) Foreign Direct Investment in Latin America: Overview and Current Status, (original English version) (partial translation into Spanish available on 4th web page of this link - click on "4" at bottom of opening page) Inter-American Development Bank (2002) (with Reuven S. Avi-Yonah), cited in Reuven S. Avi-Yonah, "A Creditable VAT?" 114 Tax Notes 793 (Feb. 19, 2007), 45 Tax Notes International 965 (Mar. 12, 2007), 2007 Worldwide Tax Daily 51-12 (Mar. 15, 2007) Allison D. Christians, "Tax Treaties for Investment and Aid to Sub-Saharan Africa: A Case Study," 71 Brooklyn L. Rev. 639 (2005) Avi Nov, "Tax Incentives for Foreign Direct Investment: The Drawbacks," 38 Tax Notes International 263 (Apr. 18, 2005), 2005 Worldwide Tax Daily 75-10 (Apr. 20, 2005) Peter D. Byrne, "Regímenes Tributarios Especiales en la Región Mercosur: Implicancias de Políticas Tributarias y de Comercio para la Integración Regional," Inter-American Development Bank (2003) Congressional Statements and Minor Commentary Three Problems Associated with Territorial Taxation, 50 Tax Notes International 1103 (June 30, 2008) Comments on U.S.-Canada Fifth Protocol and OECD Services Draft, U.S. International Tax Outlook (Feb. 7, 2008), 2008 Worldwide Tax Daily 45-9 (Mar. 5, 2008) International Tax Reform: Response to Sheppard, 117 Tax Notes 1175 (Dec. 17, 2007), 2007 Tax Notes Today 243-38 (Dec. 18, 2007), 48 Tax Notes International 1261 (Dec. 24, 2007), 2007 Worldwide Tax Daily 248-15 (Dec. 27, 2007) U.S. International Tax Outlook (weekly newsletter beginning Sept. 4, 2007) (click here for sample issue) A Projection of the Maximum Revenue Loss from Foreign Tax Credit for Value-Added Taxes, 45 Tax Notes International 969 (March 12, 2007), 2007 Worldwide Tax Daily 51-11 (Mar. 15, 2007), cited in Reuven S. Avi-Yonah, "A Creditable VAT?" 114 Tax Notes 793 (Feb. 19, 2007), 45 Tax Notes International 965 (Mar. 12, 2007), 2007 Worldwide Tax Daily 51-12 (Mar. 15, 2007) U.S. Foreign Tax Credit for VAT, slides to accompany presentation at the January 2007 ABA Tax Section meeting in Hollywood, Florida Kick-Off for Tax Reform: Tackling the Tax Code: Hearing Before the Committee on Finance, United States Senate, 109th Cong. 325-327 (Aug. 3, 2006) (statement of Martin B. Tittle) Written Statement, House Ways and Means Committee, Subcommittee on Select Revenue Measures, Hearing on The Impact of International Tax Reform on U.S. Competitiveness, June 22, 2006 Principles vs. Rules: Toward a More Fundamental Formulation of Tax Law, 42 Tax Notes International 769 (May 29, 2006); 2006 Worldwide Tax Daily 104-7 (May 31, 2006) Toward a Negative Definition of Tax Incentives, 42 Tax Notes International 403 (May 1, 2006); 2006 Worldwide Tax Daily 85-8 (May 3, 2006) Treatment of Single Limitation Loss and Overall Foreign Loss in a Sec. 965 Context, 40 Tax Notes International 1073 (Dec. 19, 2005); 2005 Woldwide Tax Daily 244-12 (Dec. 21, 2005) Written Statement, Senate Finance Committee Hearing, October 1, 2003 Written Statement, Senate Finance Committee Hearing, July 15, 2003 (.html) (48K .pdf - typescript) (8.8 MB .pdf - hearing transcript), cited in Kristin M. Byrd, "Comment [-] Can We Provide a Level Playing Field for U.S. Corporations and Increase U.S. Jobs While Repealing the Extraterritorial Income [Exclusion] Act?" 5 Houston Bus. and Tax L.J. 341, 350 n.67 (2005) Questions and Answers on VAT Creditability and ETI Repeal (2003) Questions and Answers on the Fractional FSC Sanctions (2004) The European Commission’s Proposed FSC-ETI Sanctions (2003) Follow-Up Regarding Binding Contract Relief and the Thomas ETI Repeal Bill, 32 Tax Notes International 153 (Oct. 13, 2003), 2003 Worldwide Tax Daily 198-17 (Oct. 14, 2003) Comment: Argument against Prof. Michael Graetz's Proposal, President's Advisory Panel on Federal Tax Reform (June 10, 2005) American Exporters Deserve New Tax Credit (2003) EU Switches from 'Satisfactory Progress' to a Firm Deadline, (2003) Beneficial Creations of Our Government, Wall Street Journal (Letters), Nov. 4, 2004 (responding to Harold Evans, "From Steam Engine to Search Engine," WSJ, Nov. 3, 2004) The Tax Cut and New Jobs, The New York Times (Letters), Dec. 21, 2003, sec. 3, at 2 Media Quotes Roger Russell, "Taxes Know No Borders," Accounting Today, April 19, 2010 Roger Russell, "Administration targets international tax reform," Accounting Today, June 1, 2009 Roger Russell, "International tax: The new hunt for tax havens," Accounting Today, Feb. 23, 2009 Roger Russell, "Who owns America?" Accounting Today, Oct. 6, 2008 Roger Russell, "Cost, complexity clog FIN 48 compliance," Accounting Today, Aug. 18, 2008 Roger Russell, "U.S. tax reformers need to think globally," WebCPA, Aug. 4, 2008 Roger Russell, "Tax haven legislation gaining momentum," WebCPA, April 14, 2008 Roger Russell, "Is the Tax Code unfair to hedge fund investors?" WebCPA, March 31, 2008 Kristen Parillo, "U.S. Senate ratifies German, Belgian treaties," 2007 Worldwide Tax Daily 243-1 (Dec. 18, 2007), 2007 Tax Notes Today 243-5 (Dec. 18, 2007), 117 Tax Notes 1216 (Dec. 24, 2007) Roger Russell, "TIPRA draws strong reactions," Accounting Today, June 19, 2006 (regarding the repeal of FSC-ETI binding contract grandfathering and the new CFC-to-CFC look-through rule) Roger Russell, "New regs would change the landscape for intangibles," Accounting Today, Sept. 26, 2005 (regarding transfer pricing) Roger Russell, "Whose law is it, anyway?" Accounting Today, June 6, 2005 (regarding Pasquantino v. U.S. and the Revenue Rule) Roger Russell, "IRS board and NRP signal increased compliance focus," Accounting Today, May 2, 2005 (regarding the Son of Boss tax shelter) Roger Russell, "Maximizing AJCA benefits requires tough calculations," Accounting Today, Nov. 29, 2004 Roger Russell, "For better or worse, Jobs Creation Act of '04 is here," Accounting Today, Nov. 8, 2004 Roger Russell, "American Jobs Creation Act of 2004 headed to White House," WebCPA, Oct. 13, 2004 (regarding the bill's special interest provisions) Roger Russell, "Repeal of export tax rumbles on," Accounting Today, July 12, 2004 (regarding the difficulties that will face the JOBS bill-AJC Act conferees) Roger Russell, "House Passes ETI Repeal," WebCPA, June 21, 2004 (regarding passage of H.R. 4520) Roger Russell, "JOBS sails through Senate," Accounting Today, June 7, 2004 (regarding the JOBS bill and the likely timeline for ETI repeal) Roger Russell, "U.S. feels backlash for failing to pass JOBS Act," Accounting Today, Apr. 19, 2004 (regarding the delay in repealing ETI) Conferences 2007 ABA Section of Taxation Midyear Meeting, Hollywood, FL, Jan. 18-20, 2007 (invited speaker) 2006 ABA Section of Taxation May Meeting, Washington, D.C., May 4-6, 2006 Fourth International Tax Institute, Georgetown University Law Center, March 16-17, 2006 Eighteenth Annual Institute on Current Issues in International Taxation, Washington, D.C., December 8-9, 2005 Michigan Bar Association 18th Annual Tax Conference, Plymouth, MI, May 26, 2005 2005 ABA Section of Taxation May Meeting, Washington, D.C., May 19-21, 2005 Sixteenth Annual Institute on Current Issues in International Taxation, Washington, D.C., December 11-12, 2003 International Tax Institute, Fordham University Law School, June 3-4, 2003 Bar Activities Member, State Bar of Michigan (P57978) Member, Bar of the District of Columbia Court of Appeals Member, Bar of the United States District Court for the Northern District of Texas Member, Bar of the United States District Court for the Eastern District of Michigan Vice-chair, ABA Report on Proposed Revision of Income Tax Regulations under Sections 358, 367, 884, and 6038B Dealing with Statutory Mergers or Consolidations under Section 368(a)(1)(A) Involving One or More Foreign Corporations, May 2005



Home