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).