Tom has been quoted or mentioned by name in The New York Times, The Baltimore Sun, Tax Notes, Tax Notes Today, BNA Daily Tax Report, Tax Law360, International Herald Tribune, The Kansas City Star, Financial Advisor Magazine, Chicago Lawyer, Bloomberg.com, Crain’s Health Pulse, Forbes.com, and CNNMoney.com.
Recent Development: Author of “The ‘Corporation’ Exception to Carried Interest: A Litigator’s View,” appearing at Federal Tax Notes, Vol. 169, p. 769 (Nov. 2, 2020) (5,200-word article addressing Code section 1061(c)(4)(A)). Copy viewable at Tom’s LinkedIn Profile; PDF available upon request.
Recent Development: Quote in Law360’s article on the the Federal Circuit’s recent decision in Charleston Area Medical Center, which addresses Notice 2018-18 (respecting the TCJA’s cutback to the historically favorable treatment for Carried Interest).
Recent Development: Quoted in Bloomberg/BNA’s article on the Federal Circuit’s recent decision in Charleston Area Medical Center, which addresses Notice 2018-18 (respecting the TCJA’s cutback to the historically favorable treatment for Carried Interest).
Recent Development: Views as to the recent Charleston Area Medical Center decision, and its implications for the validity of regulations promised by IRS Notice 2018-18, addressed by Tax Analysts Contributing Editor Ben Willis’ in his blog post on LinkedIn.
Quoted in Law360, “Tax Docs Irrelevant to Interest Row, US Tells 10th Cir.” Jan. 9, 2019 (pertaining to new Code section 1061(c)(4)(A))
Quoted in Bloomberg Law’s article, “IRS Clarification of Carried Interest May Face Legal Challenge,” March 22, 2018 (pertaining to new Code section 1061(c)(4)(A))
Quoted in Tax Law360 on recent decision requiring the filing of administrative claims before suing to recover additional statutory interest, Oct. 22, 2016
Author, “Litigation Finance for Tax Cases: A Win-Win for Taxpayers and Counsel,” 153 Tax Notes 713, Oct. 31, 2016
Author, “10 Situations When a CPA Should Call ‘Timeout,’” Journal of Accountancy, April/May 2015
Author, “Additional Interest on FICA-Tax Refunds Made to Teaching Hospitals: Action Required,” hfma.org, October 2014
Author, “Ruling Favors Employer Tax Refunds on Layoffs,” CFO magazine, September 25, 2012
Co-Author, “Could You Be Charged with A Crime for Failures by Prior Management to Pay Over Employment Taxes to the IRS?,” Orange County (CA) Business Journal, November 21, 2011
Author, “The Mayo Decision’s Problematic Tax Analysis,” BNA Daily Tax Report, March 17, 2011
Author, “De-Turbocharging Chevron and Mayo: What Arguments Survive Mayo to Place a Check on Federal Regulatory Overreach?,” Lexis-Nexis, April 27, 2011
Author, “Time for Teaching Hospitals to Conduct a Strategic Review of Large-Dollar Claims Seeking a Refund of Medical-Resident FICA Taxes Paid Under the 2005 Regulation,” BNA’s Health Law Reporter, August 19, 2010
Author, “Update on Next Steps for Teaching Hospitals to Recover FICA Tax Paid On Stipends Paid to Medical Residents,” Health Lawyers Weekly, June 18, 2010
Author, “Recovering FICA Tax Paid on Resident Stipends: 2010 Update,” hfm Magazine, April 1, 2010
Co-Author, “IRS Concedes That Medical Resident Stipends Are Not Subject to FICA Taxes for Quarters Before April 1, 2005: Now What?,” Health Lawyers Weekly, March 5, 2010
Co-Author, “Navigating Voluntary Disclosure in the Wake of the Government’s Assault on Undisclosed Foreign Accounts,” The Criminal Litigation Newsletter, American Bar Association, Spring 2009
Author, “Recovering FICA Tax Paid on Resident Stipends: Time for a Strategic Review,” hfm Magazine, January 2009
Co-Author, “Deductibility of Bribes, Kickbacks, Illegal Payments, Fines, and Penalties,” Tax Management Portfolio 524 (BNA/Bloomberg treatise), 2007
Co-Author, “Whose Tax Law Is It?,” Legal Times, October 16, 2006
Co-Author, “To Practice Tax Law, You Need A Patent License,” IP Law360, September 11, 2006
Co-Author, Supplement to major WG&L tax treatise regarding tax shelters (sub silentio).
Author, “The Invalidity of Reg. § 1.903-1(a) — and a Tax-Recovery Strategy Suggested by the Analysis,” Journal of Taxation of Global Transactions, Winter 2004
Author, “The Growing Controversy Over Federal Excise Tax on Long-Distance Calls,” The Tax Executive, May-June 2003
Author, “The Invalidity of the ‘For Everyone or No One’ Rule and a Tax-Recovery Strategy Suggested by the Analysis,” Tax Notes, February 1, 2003
Author, “Powerful New Arguments Against the Duplicated-Loss Provisions of the LDR,” Tax Notes, September 17, 2001
Author, Note, “Chart v. General Motors: Did It Chart the Way for Admission of Evidence of Subsequent Remedial Measures in Products Liability Actions?,” 41 Ohio St. L. J. 211 (1980) (student article in Big Ten flagship law review)
Notable Speaking Engagements
Panelist, Proposed Carried Carried Interest Regulations: Are You Ready?, November 18, 2020 (sponsored by Anchin, Block & Anchin LLP; SS&C Technologies, Inc.; and Seward & Kissel LLP).
Speaker, “New Opportunities for Challenging Dubious Treasury Regulations,” Webcast Sponsored by the Tax Committee of the ABA’s Business Law Section, March 8, 2016 (with Prof. Andy Grewal of the U. of Iowa College of Law)
Speaker, “Bringing Suit to Recover Additional Interest on FICA Refunds Previously Received,” Webinar held on April 23, 2015
Speaker, “Update on ‘Third Wave’ Medical-Resident FICA Litigation,” Webinar held on November 21, 2013
Panelist, “Litigation of Actions under Section 7408 and Related Sections, Such as Sections 7407 and 7402,” ABA Section of Taxation and Section of Real Property, Trust and Estate Law, Trust and Estate Division’s 2012 Joint Fall CLE Meeting, Boston, MA, September 14, 2012
Speaker, “The IRS’s Revised Position on Employer-Provided and Supported Cell Phones,” The John Marshall Law School’s Tax Law Lunch and Learn Series, Chicago, April 18, 2012
Panelist, “Increased Scrutiny of Tax Professionals,” The John Marshall Law School Fourth Annual Institute on the Ethics of Tax Law Practice, Chicago, May 26, 2011
Panelist, “Medical Resident FICA,” National Association of College and University Business Officers’ Tax Forum, New Orleans, LA, November 4, 2010
Speaker, “A Look Back at the IRS’s Billion-Dollar Concession of Litigation over the ‘First Bucket’ of Medical-Resident FICA Claims: A View from the Front Lines,” The John Marshall Law School, Chicago, September 15, 2010
Speaker, “FICA Tax on Severance Pay: Status of the Controversy Possible Next Steps,” Ernst and Young LLP, Chicago, July 23, 2010
Participant, SUB Pay Meeting, Internal Revenue Service’s Office of Appeals, Washington, D.C., June 9, 2010
Panelist, “Shrinking Privileges, Expanding Responsibilities,” The John Marshall Law School Center for Tax Law and Employee Benefits’ Third Annual Institute on the Ethics of Tax Law Practice, Chicago, May 25, 2010
Panelist, 29th Annual Federal Tax Institute, Chicago-Kent College of Law, Chicago, April 29, 2010
Panelist, “Medical Resident FICA and Other Employment Tax Issues,” Ernst and Young LLP, Chicago, March 24, 2010
Panelist, “Focus on Tax Controversy: Managing Risk in a Hostile Environment,” Chicago, March 16, 2010
Panelist, “Employment Tax Update,” 19th Annual Ernst and Young LLP Health Sciences Tax Conference, Las Vegas, NV, December 8, 2009
Panelist, “International Compliance Issues,” TEI’s International Tax Forum, Chicago, December 3, 2009
Speaker, “The Report of Foreign Bank and Financial Accounts: Tough New Requirements,” Strafford CLE and CPE Webinar, November 5, 2009
Speaker, “Myriad Judgment Calls: Assisting Clients Who Have Failed to File Reports of Foreign Financial Accounts,” The John Marshall Law School Center for Tax Law and Employee Benefits’ Second Annual Institute on the Ethics of Tax Law Practice, Chicago, Illinois, May 15, 2009
Speaker, “Recovering Refunds of FICA Tax Paid on Stipends Paid to Medical Residents,” Webinar, May 6, 2009
Speaker, “Issues with IRC § 6694: Understatement of Taxpayer’s Liability by Tax Return Preparer,” The John Marshall Law School Inaugural Institute on the Ethics of Tax Law Practice, Chicago, Illinois, April 29, 2008
Panelist on the proposed overhaul of Rule 26(a) of the Rules of the Court of Federal Claims. Tenth Annual Judicial Conference of the Court of Federal Claims, Kingsmill, Virginia, November 1997.
Panelist and author of materials on prerequisites to tax-refund jurisdiction in the Court of Federal Claims. Twentieth Annual Tax Law Conference of the Federal Bar Association, Washington, DC, March 1996.
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