|   | | Law Firm in New York, New York | |
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| | Address | | 1330 Avenue of the Americas | | New York, New York 10019 | | (New York Co.) | | | |
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(Main Office)
| Feingold & Alpert, L.L.P. practices in the following areas of law:
International Tax, Taxation, Federal, State and Local Tax, Resolution of Federal, State and Local Tax Controversies and Transnational Business Law including the fiscal aspects thereof. | | Firm Size: 6 | | Fred Feingold (Member) born New York, N.Y., March 29, 1946; admitted to bar, 1970, New York; 1979, U.S. Tax Court; 1980, District of Columbia; 2003, U.S. Supreme Court. Education: City College of the City University of New York (B.B.A., 1966); Brooklyn Law School (J.D., cum laude, 1969). 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). Member: The Association of the Bar of the City of New York; New York State, American and International Bar Associations; The District of Columbia Bar; International Fiscal Association. Practice Areas: Taxation; International Taxation; International Law. Email: Fred Feingold | | Mark E. Berg (Member) born St. Louis, Missouri, June 27, 1959; admitted to bar, 1985, New York and U.S. Tax Court. Education: Pennsylvania State University (B.S., summa cum laude with honors, 1981); Columbia University (J.D., 1984). James Kent Scholar; Harlan Fiske Stone Scholar. Managing Editor, Columbia Journal of Law and Social Problems, 1983-1984. Law Clerk to Judge Theodore Tannenwald, Jr., U.S. Tax Court, 1984-1985. Author: "The Treatment of Partnerships, LLC's and S Corporations under Income Tax Treaties," 1 Business Entities 20 (July/August, 1999); Checking the Box: New Proposed Regulations Would Simplify Entity Classification and Afford Planning Opportunities", 8 Journal of S Corporation Taxation 195, Winter 1997; "The RRA '93 Relief for Workouts of Troubled Real Property Debt: Impact on S Corporations and Partnerships," 5 Journal of S Corporation Taxation 399, Spring, 1994; "Resolving the Class Struggle: New Proposed One-Class-of-Stock Regulations," 3 Journal of S Corporation Taxation 267, Spring, 1992; "Both a Borrower and a Lender Be: The New "Self-Charged" Interest Rules," 3 Journal of S Corporation Taxation 194, Winter, 1992; Co-author: "New York Tax Rules May Reduce Corporate Loss Carryovers," N.Y.L.J., Dec. 12, 1991; "Whither the Branches?," 44 Tax Law Review 205, Winter, 1989; "Losses and the Partner: Toward a Rational Basis Standard," 3 Journal of Partnership Taxation 195, Fall, 1986. Co-Editor, International Taxation Department, Business Entities, 1998—. Pass-Through Entities Columnist, Journal of S Corporation Taxation, 1992-1998. Member, Board of Advisors, Journal of Limited Liability Companies, 1994-1998. Member: The Association of the Bar of the City of New York (Member, Pass-Through Entities Committee) New York State (Member, Section on Taxation) and American (Member, Section on Taxation) Bar Associations. Practice Areas: Taxation; Federal Taxation; State Taxation; Local Taxation; International Taxation; Tax Controversies. Email: Mark E. Berg | | Jonathan S. Brenner (Member) born Passaic, New Jersey, October 20, 1955; admitted to bar, 1981, New York, U.S. District Court, Southern and Eastern Districts of New York and U.S. Tax Court. Education: Hamilton College (A.B., 1977); University of Michigan (J.D., magna cum laude, 1980); New York University (LL.M., Taxation, 1984). Order of the Coif. Research Editor, University of Michigan Journal of Law Reform. Member: New York State and American Bar Associations. Practice Areas: Taxation; International Taxation. Email: Jonathan S. Brenner | | Kristin King (Member) born Naperville, Illinois, July 31, 1968; admitted to bar, 1994, Illinois; 1997, New York. Education: Clemson University (B.A., 1990); Duke University (J.D., 1993); Washington University (LL.M., Taxation, 1994). Practice Areas: Taxation. Email: Kristin King | | OF COUNSEL | | Herbert H. Alpert (Of Counsel) born Brooklyn, New York, December 22, 1932; admitted to bar, 1957, New York; 1977, District of Columbia. Education: University of Pennsylvania (B.S. Economics, 1953); Columbia University (J.D., 1956). Editor, Columbia Law Review, 1954-1956. Attorney, Office of Tax Legislative Counsel, U.S. Treasury Department, 1966-1967. Co-Editor, International Department, Journal of Taxation. Member: The Association of the Bar of the City of New York (Member, Tax Committee, 1977-1980); New York State and American Bar Associations. Practice Areas: Taxation; International Taxation. Email: Herbert H. Alpert | | Norman Sinrich (Of Counsel) admitted to bar, 1962, New York, U.S. District Court, Southern and Eastern Districts of New York, U.S. Court of Appeals, 2nd, 3rd, and Federal Circuits, U.S. Court of Federal Claims, U.S. Tax Court and U.S. Supreme Court. Education: Brooklyn College (B.A., 1960); New York University (J.D., 1962; LL.M., Taxation, 1963). Member, New York University Law Review. Professor of Law, New York University School of Law, 1979-1981. Adjunct Professor of Tax Law, New York University School of Law, 1981—. Member: The Association of the Bar of the City of New York (Member: Tax Committee, 1972-1998; Committee on Taxation of Business Entities, 1998-2002); New York State (Member: Bankruptcy Tax and Corporate Reorganization Committees) and American (Member, Taxation Section, Corporate Tax Committee, 1981-1999; 2003—) Bar Associations; International Fiscal Association. Fellow-American College of Tax Counsel. Practice Areas: Taxation; Corporate Tax; Tax Controversies; Insurance Taxation; Tax Litigation; International Taxation. Email: Norman Sinrich | | LEGAL SUPPORT PERSONNEL | | Fred Cruz (Office Administrator) |
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