"Songs of Innocence and Experience": Changes to the Scope and Interpretation of the Permanent Establishment Article in U.S. Income Tax Treaties, 1950-2010J. Ross Macdonald
A Field Guide to Cancellation of Debt IncomeMartin J. McMahon, Jr. and Daniel L. Simmons
Continuity of Business Enterprise: A Concept Whose Time Has PassedDavid F. Shores
Tax Risk to Noncontributing Shareholders from Disproportionate Capital Contributions: Red Herring or Elephant in the Room?Harvey Braverman
U.S. Trade or Business Implications of Distressed-Debt InvestingPeter A. Furci
Interpreting a Visigothic Spanish Civil Law Tradition to Trump the Internal Revenue Code: Section 6015's Uneven Application in Community Property StatesBritt Cass Steckman
Allnutt v. Commissioner: The Taxpayer's Responsibility Cara M. Cotter
Defining Willfullness: The Role of the Defendant's Ability to Pay in United States v. Easterday Elizabeth M. Fialkowski
Tenure Trap: Third Circuit Joins Sixth in Holding Tenure Buy-out Payments Subject to FICA Taxation in University of Pittsburgh v. United States Daniel C. Sale
Tax Evasion—To Convict or Collect? Can the Government Have It Both Ways Under the Expanded Definition of "With Respect to Stock" in Section 301 After Boulware v. United States? Hayley T. J. Tozeski
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Published bySection of Taxation, American Bar Associationin Collaboration with theGeorgetown University Law Center
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