Atty. Fred Feingold

Notes Editor, Brooklyn Law Review, 1968-1969

Author

• Brief Outline of U.S
• Tax Considerations Relevant to Artists, Entertainers and Athletes with a Particular Emphasis on Their Personal Appearance Income (IBA, London, March 6-7, 2006)
• The Attempted Extra Statutory Application Of "Withholding" Under Sections 1441 And 1446 In Respect Of Income Of Certain U.S
• Persons, The Mysterious Nature Of The Section 1446 Withholding Tax Liability And Certifiable Hysteria Precluding Reliance On Payee's Certificates And Other Anomalies, (June 13, 2005)
• The Complex Domestic Trust, a Potential Vehicle for Reducing the Tax on U.S
• Source Non-Effectively Connected Dividend Income of Non-U.S
• Persons and Capital Gains of Certain Corporations?, (September, 2003)
• Treaty Entitlements through the Looking Glass: Changing the Meanings but Not the Words, (April, 2001)
• Tax Planning and Pitfalls for International Entertainers Case Study: U.S
• Perspective, Section I, Source Country, Non Treaty Situation, and Outline of Comments to the General Structure of the Contract, IBA, Barcelona, September, 1999
• Article 17 - the Artiste Clause - Time for Reconsideration, (January, 1999)
• Proposed Expatriation Rules, (April, 1995)
• Entitlement to Treaty Benefits: a Comparison of the Dutch and German Solutions (September, 1994)
• Certain Tax Consideration relating to Acquisitions of U.S
• Investments by Non-U.S
• Persons, N.Y
• University, 52nd Institute of Federal Taxation, (November, 1993)
• Certain Tax Issues Relating to International Commercial Agreements, PLI, (October, 1993)
• Limitation on Benefits, an Overview (December, 1990)
• Feingold and Berg, Whither the Branches, 44 Tax Law Review No.2, 205 (1989)
• Feingold and Glicklich, An analysis of the temporary regulations under FIRPTA, Part II, 69 J. Taxation, No. 5, 348 (1988)
• Feingold and Glicklich, An Analysis of the Temporary Regulations Under FIRPTA, Part I, 69 J. Taxation, No. 4, 262 (1988)
• Source and Certain Other Jurisdictional Limitations in Light of the Tax Reform Act of 1986 (May, 1987)
• New Regime of Branch Level Taxation Now Imposed on Certain Foreign Corporations, 66 J. Taxation, No. 1, 2, (1987)
• Feingold and Schwartz, Source of Income From Sales of Personal Property, 35 Can
• Tax Journal, 473 (March-April, 1987)
• New Statutory Definition of Resident Alien under the Tax Reform Act of 1986, 44 NYU Inst. on Fed
• Tax, 46 (1986)
• Feingold and Glicklich, Broad FIRPTA Withholding Rules are Bound to Affect Canadians, 33 Can Tax Journal, No. 1, 170-88 (1985)
• Feingold and Fishman, Has the 30 Per Cent
• Tax on Portfolio Interest Been Eliminated?
• The British Tax Review, 1985 No. 4
• Feingold and Silbergleit, Revenue Rulings 84-152 and 84-153: Treaty Shopping - Let the Buyer Beware, 33 Can
• Tax Journal, no. 1, 158 (January-February, 1985)
• Feingold and Glicklich, Broad FIRPTA Withholding Rules are Bound to Affect Canadians, 33 Can
• Tax Journal, No. 1, 170 (January-February, 1985)
• Feingold and Fishman, DRA's Elimination of Withholding Tax on Portfolio Interest, 65 J. Taxation No. 3, 170 (1985)
• Feingold and Glicklich, Onerous FIRPTA Reporting Requirements Replaced by New Broad Withholding Rules, 61 J. Taxation No. 5, 298 (November, 1984)
• An Analysis of the New Law Tests for an Alien's Status as a U.S
• Resident, 61 J. Taxation, No. 4, 228 (1984)
• FIRPTA - An Overview of the New Proposed Regulations, 32 Can
• Tax Journal, No. 1, 147 (January-February, 1984)
• Feingold and Alpert with McDonald, Proposal Before Congress to Define U.S
• Resident Status, 31 Can Tax Journal No. 5, 853 (September-October, 1984)
• Feingold and Fishman, Recent Procedural Changes Relating to Restructuring Holdings in Foreign Corporations May Have Substantive Significance, 31 Can
• J. Taxation, No. 3, 469 (May- June 1983)
• The Viability of the Personal Service Corporation- the Tax Court is Once Again Heard From, 30 Can
• Tax Journal, No. 1, 107-12 (1982)
• Feingold and Alpert, Observations on the Foreign Investment in Real Property Tax Act of 1980, 1 Va
• Law Review, No. 1, 105 (1981)
• The Source of a Guarantor's Income, 29 Can
• Tax Journal, No. 6, 233-37 (1981)
• The Use of Substantial Equipment or Machinery at Any Time During the Year as a Permanent Establishment, 28 Can
• Tax Journal, No. 2, 222 (1980)
• Alpert and Feingold, Tax Reform Act Toughens Foreign Transfer Provisions of 1491, and Liberalizes 367, 46 J. Taxation 2 (1977)