In the 100-year history of the ABA’s Infrastructure and Regulated Industries Section (IRIS), the increasing complexity and frequency of change in the corporate income tax has been a relative constant. Such changes have increased exponentially over the course of the twentieth century and slowed only slightly by recent legislative gridlock. However, the changing impact of the corporate income tax on infrastructure and regulated industries can be seen more clearly though the lens of the transition of these industries from government-provided services to regulated private ownership and then later to ownership by conglomerates of regulated and unregulated businesses. This progression and development of the infrastructure industries provides the context in which income tax developed from an irrelevance to a predicable expense and, finally, to a significant financial risk as well as a financial planning tool. Accordingly, the significant change in the role played by tax lawyers advising these industries must be considered in relation to these historic developments.
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