• Tax-free corporate reorganizations of publicly traded and closely held corporations, including banks, construction companies, family investment companies, and other operating companies.
  
  
• Structuring and obtaining favorable rulings from the IRS on corporate spinoff transactions.
  
  
• Obtaining a determination of tax-exempt status from the IRS for the first integrated health care delivery system approved by the IRS.
  
  
• Advising on the conversion of tax-exempt organizations to proprietary corporations. Forming a limited liability company and affiliated professional corporation through which two tax-exempt health systems conduct a large, regional primary care network.
  
  
• Structuring the tax-free consolidation of licensed health plans. Reorganization of multinational real estate holdings for Antilles-based parent with worldwide subsidiaries.
  
  
• Tax planning for long-term multinational natural resource investments in Canada and New Zealand.
  
  
• Representation of multinational fishing company in IRS transfer pricing audit.
  
  
• Representation of developers of mixed use projects involving new construction and/or rehabilitation of older or historic structures in Seattle and Portland.

Recent Publications

Members of the Tax Section have published the following recent articles in national tax publications:

• Related-Party Sales Can Produce Unexpected Tax Results, Taxation for Lawyers, 1997
  
  
• Transfer Pricing Penalties: A Tougher Standard, The Practical Accountant, 1997
  
  
• IRS Proposes New Rules for Allocation of Depreciation Recapture Income Among Partners, Corporate Tax and Business Planning Review, 1997
  
  
• IRS Revisits Application of Self-Employment Tax Rules to Limited Partners and Members of Limited Liability Companies, Corporate Tax and Business Planning Review, 1997
  
  
• Business Operations in the Republic of Korea, Bureau of National Affairs, revised 1997
  
  
• Proposed Regulations Address Gain Recognition on Partnership Distributions of Marketable Securities, Corporate Tax and Business Planning Review, 1996
  
  
• Transfer Pricing and Formulary Apportionment, Taxes, 1996
  
  
• "Medical Foundation" Action in Medical Practice Consolidation: Structural and Legal Issues, Bureau of National Affairs, 1996
  
  
• Creating Tax-Exempt Medical Practices in Integrated Delivery Systems, The Journal of Oncology Management and The Journal of Cardiovascular Management, 1996
  
  
• Conversions To and From Nonprofit Status, The Exempt Organizations Tax Review, 1995
  
  
• Physician Control of PHOs: What are the Limits?, Northern and Southern California Medicine, 1995
  
  
• Trends in Recently Negotiated Tax Treaties Between Developed and Developing Countries, United Nations Secretariat, 1995

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