US and International Taxation Publications

Panel Chair and Speaker at National Tax Institutes

JOSEPH CALIANNO INTERVIEWD BY JERALD DAVID AUGUST

Joseph Calianno Interviewed by Jerald David August, Corporate Taxation (WG&L), May/Jun 2025

83RD INSTITUTE ON FEDERAL TAXATION - NEW YORK AND CALIFORNIA
NYU, Topics: (1) Closely-Held Businesses, (2) Ethics, (3) and Mergers and Acquisitions of Closely Held S and C Corporations in Private Equity, Up-C and Domestic and Cross Border Spac Transactions, (4) The Tax Advisor as Provider of Tax Insurance and Penalty Protection: Ethical Guardrails and Limits and Malpractice Risks, October 24, 2024 and November 21, 2024

MITIGATING CORPORATE-LEVEL TAXES FOR C AND S CORP SHAREHOLDERS: “LOOKING THROUGH THE BIG WINDOWS”
American Law Institute, ALI-CLE Course Materials. July 29, 2024. WESTLAW: VCGG0729 ALI-CLE 1

SALES AND OTHER DISPOSITIONS OF PARTNERSHIP INTERESTS: LOOKING OUT FOR THE MIXING BOWLS AND OTHER GREMLINS IN SUBCHAPTER K
American Law Institute, ALI-CLE Course Materials. December 12, 2023. WESTLAW: VCFG1212 ALI-CLE 31

ASSESSMENTS AND COLLECTION OF INCOME TAX FROM PARTNERSHIPS, PARTNERS, AND FORMER PARTNERS UNDER THE BBA PARTNERSHIP AUDIT RULES, PART TWO: TAKE A CLOSE LOOK AT THE CEASE TO EXIST RULE!!
American Law Institute, ALI-CLE Course Materials. December 12, 2023. WESTLAW: VCFG1212 ALI-CLE 183

THE ‘NO-LOOK, JUST PASS IT’ LEGISLATION TO PREVENT ABUSE OF PARTNERSHIPS BY WEALTHY INVESTORS AND MEGA-CORPORATIONS TO AVOID PAYING TAX
American Law Institute, ALI-CLE Course Materials. December 12, 2023. WESTLAW: VCFG12

PARTNERSHIP INTEREST SALES AND REDEMPTIONS: TAX TRAPS, “MIXING BOWLS,” AND CHALLENGES IN SUBCHAPTER K SLIDES
American Law Institute; ALI-CLE Course Materials. December 12, 2023. WESTLAW: VCFG1212 ALI-CLE 1

PREPARING FOR A TAX CONTROVERSY: GEARING UP FOR INCREASED TAX AUDITS AND INVESTIGATIONS - SLIDES
American Law Institute; ALI-CLE Course Materials. December 7, 2021. WESTLAW: VCDG1207 ALI-CLE 1

PROCEEDING WITH A VALUATION CASE INVOLVING CLOSELY HELD BUSINESS INTERESTS BEFORE THE UNITED STATES TAX COURT (PARTS 1 - 3)
American Law Institute, ALI-CLE Course Materials. December 7, 2021. WESTLAW: VCDG1207 ALI-CLE 69

PROPOSED REGULATIONS TO SECTION 199A
American Law Institute, ALI-CLE Course Materials. April 16, 2019. WESTLAW: VCAG0416 ALI-CLE 113

ATTORNEY-CLIENT PRIVILEGE AND WORK PRODUCT DOCTRINE IN TAX CONTROVERSIES
American Law Institute, ALI-CLE Course Materials December 11, 2018. WESTLAW VCAG1211 ALI-CLE 1

INTERNATIONAL TAX CHANGES UNDER TCJA 2017
American Law Institute, ALI-CLE Course Materials. January 18, 2018. WESTLAW: VCZG0118 ALI-CLE 57 and March 14, 2018. WESTLAW: VCZG0314 ALI-CLE 119

IRS SCHEDULE UTP FOR FORM 1120
American Law Institute, ALI-CLE Course Materials. December 15, 2017. WESTLAW: VCZG1215 ALI-CLE 171

IRS DISCLOSURE STATEMENT FORM 8275
American Law Institute, ALI-CLE Course Materials. December 15, 2017. WESTLAW: VCZG1215 ALI-CLE 167

PETITION TO QUASH IRS SUMMONS FOR PRODUCTION OF TAX ACCRUAL WORKPAPERS: WELLS FARGO & CO V. U.S.
American Law Institute, ALI-CLE Course Materials December 15, 2017. WESTLAW: VCZG1215 ALI-CLE 175

FEDERAL INCOME TAXATION OF SINGLE MEMBER ENTITIES: “TAX NOTHINGS”
American Law Institute, ALI-CLE Course Materials. February 6, 2017. WESTLAW: VCYG0125 ALI-CLE 1

THE TEFRA PARTNERSHIP AUDIT RULES REPEAL: PARTNERSHIP AND PARTNER IMPACTS
American Law Institute, ALI-CLE Course Materials June 7, 2016. WESTLAW: VCXG0523 ALI-CLE 1

ELECTING SUBCHAPTER S: BENEFITS AND PERILS FOR THE UNWARY SLIDES
American Law Institute, ALI-CLE Course Materials. December 8, 2015. WESTLAW: VCXG1208 ALI-CLE 1

FEDERAL INCOME TAXATION OF SINGLE MEMBER ENTITIES: “TAX NOTHINGS”
American Law Institute, ALI-CLE Course Materials. June 30, 2015. WESTLAW: VCWGO630 ALI-CLE 113

EXPATRIATION OF U.S. CITIZENS AND LONG-TERM U.S. RESIDENTS
American Law Institute, ALI-CLE Course Materials March 31, 2015. WESTLAW: VCWG0331 ALI-CLE 1

SELECTED PARTNERSHIP FORMATION ISSUES INCLUDING SORTING OUT THE MIXING BOWL PROVISIONS
American Law Institute, ALI-ABA Course of Study January 12 - 13, 2012 WESTLAW: ST018 ALI-ABA 89

Selected Income Tax Considerations Concerning Choice of Entity for Conducting Business Operations Outside the United States
American Law Institute, ALI-ABA CLE May 7, 2010. 2010 ABATAX-CLE 0507080

UNDERSTANDING FIN 48, ACCOUNTING FOR UNCERTAINTY IN INCOME TAXES, AND RESULTING IMPLICATIONS UNDER SARBANES-OXLEY
American Law Institute, The Practical Tax Lawyer Summer 2008 22 No. 4 Prac. Tax Law. 19

HEDGE FUNDS—STRUCTURE, REGULATION, AND TAX IMPLICATIONS: PART I. STRUCTURE AND REGULATION
(Parts 1 & 2) Journal of Business Entities, (July/August) (Sept/Oct), 2006 8 No. 4 Bus. Entities 14, 8 No. 5 Bus. Entities 06

COMMENTS ON ADVANCE NOTICE OF PROPOSED RULEMAKING UNDER SECTION 263(A) OF THE INTERNAL REVENUE CODE RELATED TO CAPITALIZATION ISSUES REGARDING EXPENDITURES INCURRED IN ACQUIRING, CREATING OR ENHANCING INTANGIBLE ASSETS
ABA Section of Taxation, The Tax Lawyer Fall, 2002 56 Tax Law. 269

Publications for National Law Journals and law Reviews (Partial List)

TAX COURT REJECTS LOPER BRIGHT-INSPIRED CHALLANCE OF COST-SHARING REGULATIONS WHERE NO CSA COMPARABLE IN THE METAVERSE
Corporate Taxation, September/October 2025 52 WGL-CTAX 05

ONE BIG BEAUTIFUL BILL ACT ENACTED INTO LAW: INITIAL OBSERVATIONS ON BUSINESS AND INTERNATIONAL TAX PROVISIONS
Corporate Taxation, September/October 2025 52 WGL-CTAX 05

BRANCH OPERATIONS IN THE UNITED STATES BY FOREIGN CORPORATIONS: THE BASIC BUILDING BLOCKS WHEN "BRANCHING-IN" THE U.S.A.!
Corporate Taxation, July/August 2025 52 WGL-CTAX 05

TRACKING THE PTEP ACCOUNT FOOTPRINTS OF THE CONTROLLED FOREIGN CORPORATION MONSTER: THE SERVIE ISSUES PTEP PROPOSED REGULATIONS
Journal of International Taxation, March/April 2025 51 WGL-CTAX 05

SUPREME COURT REELS-IN THE CHEVRON DOCTRINE AND THEN FEASTS AT THE CORNER POST CAFE COURTESY OF MESSRS. MARBURY-MADISON
Corporate Taxation, September/October 2024 51 WGL-CTAX 05

SUPREME COURT UPHOLDS THE CONSTIUTIONALITY OF SECTION 965, THE MANDATORY REPATRIATION TAX, IN MOORE
Corporate Taxation, July/August 2024 51 WGL-CTAX 01

TAX COURT VALIDATES BLOCKED INCOME TRANSFER PRICING REGULATION IN 3M COMPANIES: CHEVRON DEFERENCE OVERRIDES SUPREME COURT'S DECISION IN FIRST SECURITY BANK
Corporate Taxation, July/August 2024 51 WGL-CTAX 01

POLICING THE U.S. COASTLINE FOR TAX-FREE REPATRIATIONS OF FOREIGN EARNINGS AND ASSET BASIS: PROPOSED REGULATIONS ISSUED UNDER SECTION 367(B)
Corporate Taxation, May/June 2024 51 WGL-CTAX 01

THE EXPANDING REACH OF U.S. TRADE OR BUSINESS UNDER SECTION 864: AGENT'S ACTIVITIES IN UNITED STATES IMPUTED TO OFFSHORE PRIVATE EQUITY FUND BY TAX COURT IN YA GLOBAL INVESTMENTS, LP
Corporate Taxation, March/April 2024 51 WGL-CTAX 01

CODIFICATION OF ECONOMIC SUBSTANCE DOCTRINE ALLOWS FEDERAL DISTRICT COURT TO OVERRIDE APPLICATION OF SECTION 351 AND BLOCK DIVIDENDS RECEIVED DEDUCTION UNDER MISMATCH OF EFFECTIVE DATE PARLAY

Corporate Taxation, Jan/Feb 2024 51 WGL-CTAX 01

FIRST CIRCUIT COURT OF APPEALS AFFIRMS TAX COURT IN TIMBERLAND (TBL LICENSING LLC): FULL INCLUSION OF GAIN REQUIRED WHERE “DECEASED” U.S. TARGET CORPORATION CONSTRUCTIVELY TRANSFERS VALUABLE INTANGIBLES AS PART OF AN OUTBOUND TYPE F REORGANIZATION
Corporate Taxation, Nov/Dec 2023 50 WGL-CTAX 10

THE DEBT CANCELLATION CULTURE OF SECTION 108: TAX HURDLES FOR PARTNERSHIPS ENGAGED IN DEBT WORKOUTS
Corporate Taxation, Sept/Oct 2023 50 WGL-CTAX 08

TAX COURT IN FARHY HOLDS U.S. TREASURY AND IRS LACK AUTHORITY TO ASSESS DELINQUENT INTERNATIONAL INFORMATION RETURNS
Corporate Taxation, July/August 2023 50 WGL-CTAX 46

THE INBOUND FOREIGN CORPORATION: KNOWING WHEN ITS INCOME IS U.S. EFFECTIVELY CONNECTED INCOME
(Parts 1 and 2) Corporate Taxation, (May/June) (July /August), 2023 50 WGL-CTAX 03

THE ‘NO-LOOK, JUST PASS IT’ LEGISLATION TO PREVENT ABUSE OF PARTNERSHIPS BY WEALTHY INVESTORS AND MEGA-CORPORATIONS TO AVOID PAYING TAX
Corporate Taxation, 2023 WESTLAW VCFG 1212 ALI-CLE 165

ASSESSMENTS AND COLLECTION OF INCOME TAX FROM PARTNERSHIPS, PARTNERS AND FORMER PARTNERS UNDER THE BBA PARTNERSHIP AUDIT RULES
Corporate Taxation, January/February 2022 49 WGL-CTAX 03

DEMYSTIFYING THE 20 PERCENT DEDUCTION FOR QUALIFIED BUSINESS INCOME UNDER SECTION 199A (PARTS 1& 2)
American Law Institute, The Practical Tax Lawyer. May & September 2021 35 No. 4 Prac. Tax Law. 35 & 49,

PRESIDENT BIDEN'S "MADE IN AMERICA" TAX PLAN: REVERSING THE INTERNATIONAL TAX BENEFITS EXTENDED TO U.S. CORPORATIONS UNDER THE TCJA
Corporate Taxation, May/June 2021. 48 WGL-CTAX 04

PROCEEDING WITH A VALUATION CASE INVOLVING CLOSELY HELD BUSINESS INTERESTS BEFORE THE UNITED STATES TAX COURT (PARTS 1, 2 and 3)
American Law Institute, The Practical Tax Lawyer September 2020 -March 2021.

TAX CONTROVERSIES AND LITIGATION UNDER THE NEW CENTRALIZED PARTNERSHIP AUDIT RULES: ARE YOU AND YOUR CLIENTS READY? (PARTS 1&2 1)
American Law Institute, The Practical Tax Lawyer March 2020 34 No. 2 Prac. Tax Law. 35

U.S. TAXATION MAY DRIVE MORE CITIZENS AND LONG-TERM RESIDENTS TO BECOME TAX REFUGEES
American Law Institute, The Practical Tax Lawyer November 2019 34 No. 1 Prac. Tax Law. 21

THE PROPOSED GILTI REGULATIONS UNDER SECTION 951A
Corporate Taxation, March/April 2019 46 WGL-CTAX 03

TAX CUTS AND JOBS ACT OF 2017 INTRODUCES MAJOR REFORMS TO THE INTERNATIONAL TAXATION OF U.S. CORPORATIONS
American Law Institute, The Practical Tax Lawyer Winter 2018 32 No. 2 Prac. Tax Law. 43

NEW FINAL AND PROPOSED REGULATIONS ON THE CENTRALIZED PARTNERSHIP AUDIT REGIME
Corporate Taxation, July/August 2018 45 WGL-CTAX 3

THE REPEAL AND REPLACEMENT OF THE TEFRA PARTNERSHIP AUDIT RULES
Practical Tax Lawyer, Winter 2017 31 No. 2 Prac. Tax Law. 47

TAX COURT REJECTS REV. RUL. 91-32, HOLDS FOREIGN PARTNER'S GAIN FROM REDEMPTION NOT ECI
Corporate Taxation, November/December 2017. WESTLAW: 44 WGL-CTAX 3

DRAFTING PARTNERSHIP AGREEMENTS: THE NEW PARTNERSHIP REPRESENTATIVE AND THE OUTGOING TAX MATTERS PARTNER
Corporate Taxation, Sept/Oct 2017 44 WGL-CTAX 3

THE NEW PARTNERSHIP AUDIT RULES: GUIDANCE NEEDED
Corporate Taxation, January/February, 2017 44 J. Corp. Tax'n 3

TAX PLANNING FOR S CORPORATIONS: MERGERS AND ACQUISITIONS INVOLVING S CORPORATIONS (PARTS 1 & 2)
American Law Institute, The Practical Tax Lawyer Spring 2016 30 No. 3 Prac. Tax Law. 31

ALTERA AND COST-SHARING REQUIREMENTS UNDER SECTION 482—ANOTHER TAX COURT REBUKE TO THE IRS
Journal of Business Entities, January/February 2016 18 No. 1 Bus. Entities 04

CORPORATE EXPATRIATION TRANSACTIONS AND THE ANTI-INVERSION RULES
Journal of Business Entities, September/October 2014 16 No. 5 Bus. Entities 16

INSIDE SECTION 897: INVESTMENTS AND DISPOSITIONS OF U.S. REAL PROPERTY INTERESTS BY NONRESIDENTS
Journal of Business Entities, November/December 2011 13 No. 6 Bus. Entities 04

MANDATORY DISCLOSURE OF UNCERTAIN TAX POSITIONS ON INCOME TAX RETURNS FILED BY CORPORATE TAXPAYERS: THE IRS'S NEW WEAPON
American Law Institute, The Practical Tax Lawyer Winter 2011 25 No. 2 Prac. Tax Law. 7

THE UNCERTAIN STATE OF UNCERTAIN TAX POSITIONS
Corporate Taxation, November/December 2011 38 J. Corp. Tax'n 18

THE DISCOVERY STATUS OF TAX ACCRUAL WORKPAPERS AFTER TEXTRON
Business Entities, January/February, 2011 2 No. 1 Bus. Entities 10

CHANGES IN U.S.-CANADA INCOME TAX TREATY POSE HAZARDS
Journal of Business Entities, January/February 2011 13 No. 1 Bus. Entities 24

THE CODIFICATION OF THE ECONOMIC SUBSTANCE DOCTRINE, PARTS 1 & II
Journal of Business Entities, (Sept/Oct) (Nov/Dec 2010), 12 No. 5 and 12 No. 6 Bus. Entities 4

ABILITY OF IRS TO DISCOVER TAX ACCRUAL AND FIN 48 WORKPAPERS
Journal of Business Entities, November/December 2008 10 No. 6 Bus. Entities 4

CHOICE OF ENTITY FOR ENGAGING IN BUSINESS OPERATIONS OUTSIDE THE UNITED STATES
Journal of Business Entities, March/April 2008 10 No. 2 Bus. Entities 4

INCOME TAX ASPECTS OF FORMING, OPERATING, AND EXITING FLPS
Estate Planning, April 2007 34 Est. Plan. 13

THE IRS CONTINUES ITS SECTION 2036 ASSAULT ON FAMILY LIMITED PARTNERSHIPS
Journal of Business Entities, (Sept/Oc. 2005) (Jan/Feb 2006) 7 No. 5 Bus. Entities 20 (Part1); 8 No. 1 Bus. Entities (part 2).

THE REGULATION OF TAX PROFESSIONALS BY THE INTERNAL REVENUE SERVICE IN A POST-ENRON WORLD (WITH FORMS)
American Law Institute, The Practical Tax Lawyer Fall 2005 20 No. 1 Prac. Tax Law. 7

TAX IMPLICATIONS OF U.S. PERSONS ENGAGING IN BUSINESS OPERATIONS IN BRAZIL
American Law Institute, The Practical Tax Lawyer Spring 2011 25 No. 3 Prac. Tax Law. 17

FINAL HUBERT REGS. FIX BOUNDARIES FOR DEDUCTING ADMINISTRATION EXPENSES
Estate Planning, June 2000 27 Est. Plan. 195

BENEFITS AND BURDENS OF SUBCHAPTER S IN A CHECK-THE-BOX WORLD
Florida Tax Review, 1999 4 Fla. Tax Rev. 287

ARTIFICIAL VALUATION OF CLOSELY HELD INTERESTS: SEC. 2704
Estate Planning, November/December 1995 22 Est. Plan. 339

THE ATTORNEY-CLIENT PRIVILEGE AND WORK-PRODUCT DOCTRINE IN FEDERAL TAX CONTROVERSIES
Journal of Taxation, October 1995 83 J. Tax'n 197

FAIRNESS WILL BE THE HALLMARK OF THE TAX INCREASES NEEDED TO REDUCE THE DEFICIT AND FUND HEALTH CARE REFORM

Journal of Taxation April, 1993 78 J. Tax’n 200

IRS SEEMS UNSURE OF THE ESTATE PLANNING CONSEQUENCES OF LOAN GUARANTEES
Journal of Taxation, March 1992 76 J. Tax'n 130

GUARANTEES AND THE MARITAL DEDUCTION: MORE ON 9113009
Journal of Taxation, September, 1991 75. J. Tax'n 191

IS A BUSINESS PURPOSE REQUIRED FOR AT-RISK AMOUNTS OF RECOURSE DEBT?
Journal of Taxation, February 1989 70 J. Tax'n 112

CORPORATE-LEVEL TAXES ON S CORPORATIONS AFTER THE TAX REFORM ACT OF 1986
Journal of Partnership Taxation Summer, 1987 4 J. Partnership Tax'n 91

GOODS AND SERVICES TEST FOR TRADE OR BUSINESS REJECTED BY SUPREME COURT
Journal of Taxation, May 1987 66 J. Tax'n 298