Mark E. Berg

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: "Tax Department Reads Taxpayer Residency Victory Narrowly," N.Y.L.J., Aug. 11, 2014; "New York's High Court Eases Residency Trap," 72 State Tax Notes 335, May 12, 2014; "Determining Which Taxes are Prohibited Direct Taxes After NFIB," 138 Tax Notes 205, Jan. 14, 2013; "Bar the Exit (Tax)!: Section 877A, The Constitutional Prohibition Against Unapportioned Direct Taxes and the Realization Requirement," 65 Tax Lawyer 181, Winter 2012; "Judicial Deference to Tax Regulations: A Reconsideration in Light of National Cable, Swallows Holding, and Other Developments," 61 Tax Lawyer 481, Winter 2008; "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.