Section of Taxation Publications


VOL. 63
NO. 2
WINTER 2010

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ARTICLESSection Members Only

"Songs of Innocence and Experience": Changes to the Scope and Interpretation of the Permanent Establishment Article in U.S. Income Tax Treaties, 1950-2010
J. Ross Macdonald

Full Article

A Field Guide to Cancellation of Debt Income
Martin J. McMahon, Jr. and Daniel L. Simmons

Full Article

Continuity of Business Enterprise: A Concept Whose Time Has Passed
David F. Shores

Tax Risk to Noncontributing Shareholders from Disproportionate Capital Contributions: Red Herring or Elephant in the Room?
Harvey Braverman

Full Article

U.S. Trade or Business Implications of Distressed-Debt Investing
Peter A. Furci

Full Article
NOTES
 

Interpreting a Visigothic Spanish Civil Law Tradition to Trump the Internal Revenue Code: Section 6015's Uneven Application in Community Property States
Britt Cass Steckman

Full Article

Allnutt v. Commissioner: The Taxpayer's Responsibility
Cara M. Cotter

Full Article

Defining Willfullness: The Role of the Defendant's Ability to Pay in United States v. Easterday
Elizabeth M. Fialkowski

Full Article

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

Full Article

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

Full Article

Section members may also view this issue of The Tax Lawyer in its entirety .


 
 

Published by
Section of Taxation, American Bar Association
in Collaboration with the
Georgetown University Law Center

 

If you are an ABA member, you can receive The Tax Lawyer and the Section NewsQuarterly, (both quarterly publications) when you join the Section of Taxation . Anyone can subscribe to The Tax Lawyer by contacting the ABA Service Center.