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59 Tax Executive 1 (2007)

handle is hein.journals/taxexe59 and id is 1 raw text is: The Tax Executive (ISSN 0040-0025), Professional Journal
of Tax Executives Institute, is published bimonthly by Tax
Executives Institute, Inc. President, David L Bernard, Kim-
berly-Clark Corporation • Senior Vice President, Robert
J. McDonough, Polaroid Corporation ° Secretary, Vincent
Alicandri, Hydro One Networks Inc. ° Treasurer, Neil
Traubenberg
C 2007 Tax Executives Institute, Inc. All rights reserved.
Subscriptions: $120 per year U.S. and Canada. Other
countries $145 per year. Must be U.S. funds. Address: The
Tax Executive, 1200 G Street, N.W., Suite 300, Washington,
D.C. 20005-3814, phone 202.638.5601.
For advertising and publication information, contact The Tax
Executive, 1200 G Street, N.W., Suite 300, Washington, D.C.
20005-3814, phone 202.638.5601. POSTMASTER: Send ad-
dress changes to The Tax Executive (at the address above).
The views expressed in The Tax Executive are those of the
authors and advertisers and may not reflect the official policy
of Tax Executives Institute or The Tax Executive. No endorse-
ment of those views should be inferred.

Chapter News ..................... 18

JANUARY-FEBRUARY 2007

THE TAX EXECUTIVE
The Professional Journal of Tax Executives Institute, Inc.
Every man owes some of his time to the upbuilding of the profession to which he belongs.
-Theodore Roosevelt
News Stories
12      European Chapter Meeting Melds Institute's Education, Networking, and
Advocacy Goals
13     IRS Clarifies Taxation of Patent Cross Licenses
FIN 48: Practical Considerations and Implementation Issues
14     Year-End Guidance on 482 Services Regulations Addresses TEI Concerns
IRS Commissioner Congratulates IRSAC Members
15     TEI Urges Delayed Implementation of FIN 48
17     TEI Midyear Conference to Feature New Ways and Means Chairman
Rangel, Other Key Officials
Feature Articles
25      A Conversation with the New Chief of Appeals: An Interview with Sarah
Hall Ingram
by James A. Dougherty and Melody Twigg
33      Do You Know Where Your Employees' Wages Are? New Section 199 W-2
Wage Limitation Guidance
By David Auclair, Mel Schwarz, and Richard Shevak
43      Legal and Practical Issues in Applying FIN 48
By Brian E. Andreoli, David Colker, and Michael S. Lebovitz
49      Measuring Tax Benefits under FIN 48 - Eliminating Some of the Agita
By William Garofalo and Mark Valente
55      Let's Combine the Income and Payroll Taxes into a Rational Tax System
By Jonathan Barry Forman
Technical Submissions
57      Announcement 2006-50: Covered Services under the Services Cost Method
of Proposed Section 482 Services Regulations
58      TEI's Comments on Proposed Regulations Relating to the Treatment of Ser-
vices under Section 482
65      Canadian Excise Tax Liaison Meeting
67      Pending Canadian Excise Tax Issues
70      Canadian Income Tax Laison Meeting
77      Pending Canadian Income Tax Issues
83      Proposal to Delay Effective Date for FIN 48
85      Proposed Regulations on Capitalization of Expenditures Related to Tangible
Property
94      TEl - LMSB Liaison Meeting
97      TEl - IRS Liaison Meeting
98      TEI - Treasury Department Liaison Meeting
THE TAX EXECUTIVE is indexed in the Harvard Law School Library Annual Legal Bibliography, Stanford University Index to
Periodical Articles Related to Law, The Ten-Year Index to Periodical Articles Related to Law (Glanville), AICPA Accountants
Index, Commerce Clearing House Federal Tax Articles, Index to Federal Tax Articles (Warren, Gorham & Lamont), Public
Affairs Information Service, and Information Access Company. Microfilm/CD ROM editions distributed by Ebsco Publishing
Office, 83 Pine Street, P.O. Box 2250, Peabody, MA 01960, USA; University Microfilm International, 300 North Zeeb Road,
Ann Arbor, MI 46106, USA, Phone: 800.521.0600; 18 Bedford Row, London, WCl R4EJ, England; and Information Access
Company, One Davis Drive, Belmont, CA 94002, USA. Single copies and back issues available from: William S. Hein &
Co., Inc., 1285 Main Street, Buffalo, NY 14209, Phone: 800.828.7571, Fax: 716.883.8100.

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