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Podcasts

Patrick M. Cox is Chair of Brown Rudnick’s Tax Group. He has extensive experience in general tax planning including issues of partnership, real estate, international and corporate taxation. In his podcasts, he offers thoughts and commentary on a range of timely tax-related topics.

For more information regarding the latest tax updates, please subscribe to Brown Rudnick's tax alert e-mails or our tax RSS feed. These podcasts may be used for informational purposes only. They are not legal advice nor do they represent the views of any person other than the speaker(s).
 

Voluntary Disclosure 2011 New
February 18, 2011
BY
PATRICK M. COX

The IRS has launched another voluntary disclosure program for offshore accounts...

 

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TAGS:
International, Tax Controversy & Compliance, Partnerships
-----------------
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RBIL Carryback
February 16, 2011
BY
PATRICK M. COX

Certain post-ownership change losses may not be available to a corporation...

 

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TAGS:
Bankruptcy & Corporate Restructuring, Corporate Finance & Distressed Debt
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Spin-Off (Credit)
February 16, 2011
BY
PATRICK M. COX

Tax-free spin-offs can be used to enhance a corporation's ability to borrow...

 

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TAGS:
Bankruptcy & Corporate Restructuring, Corporate Finance & Distressed Debt, Hedge Funds- Private Equity Funds- & Venture Capital Funds, M&A & Business Tax Issues
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U.S. Real Estate Trade or Business Implications to Foreign Investors
December 17, 2010
BY
PATRICK M. COX

Foreign investors' should be aware of the tax implications of investing in U.S. real estate...

 

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TAGS:
Hedge Funds- Private Equity Funds- & Venture Capital Funds, International, Partnerships, Real Estate
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REMICs and Loan Modifications
NOVEMBER 11, 2010
BY
PATRICK M. COX

Modifying loans held by REMICs should be done so as to comply with the tax-free safe harbors...

 

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TAGS:
Bankruptcy & Corporate Restructuring, Corporate Finance & Distressed Debt, Hedge Funds- Private Equity Funds- & Venture Capital Funds, Real Estate
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Impact of Section 338(g) Elections on Controlled Foreign Corporations
November 10, 2010
BY
PATRICK M. COX

A purchaser's Section 338 election may have hidden consequences to selling shareholders...

 

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TAGS:
International, M&A & Business Tax Issues
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Digital Goods Sales Tax
November 10, 2010
BY
PATRICK M. COX

Companies that sell computer software and digital goods should be aware of varying sales tax treatment...

 

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TAGS:
State & Local Taxes
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Foreign Investment in Real Property Tax Act (FIRPTA) Implications for Foreign Investors
November 4, 2010
BY
PATRICK M. COX

Distressed corporations may inadvertently trigger FIRPTA withholding obligations...

 

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TAGS:
International, Real Estate
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