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Vol. 36 No. 2 - Winter 2017


From the Chair

At Court


Rio Tinto Alcan v. The Queen: Welcome Expansion of the Canadian Tax Deductibility of M&A Transaction Expenses

In a welcome decision for Canadian acquirors and targets, the Tax Court of Canada recognized, in Rio Tinto Alcan Inc. v The Queen, that certain “oversight expenses”—including certain investment banking and other professional advisory fees—should be deductible in the context of M&A transactions.

Practice Points


SALT Committee Update on Partnership Audit Rules, Work with MTC and States

Partnership tax aficionados will recall that Congress passed the Bipartisan Budget Act of 2015 (the BBA) as amended by the PATH Act of 2015, in record time. That law established a new partnership audit and assessment regime and repealed prospectively the current TEFRA partnership audit rules. Even though more than a year has passed, much remains unknown—both at the federal and the state level.

Pro Bono Matters


Making a Difference in Pro Bono Tax Cases

For this edition of Pro Bono Matters, I thought it would be interesting to write about some of the tax cases that have been handled on a pro bono basis. Most cases are settled short of trial, and therefore the tremendous results obtained by pro bono volunteers are not publicized. Nevertheless, there have been several reported opinions in the past that are noteworthy and important for the specific taxpayers and the low-income taxpayer community as a whole.

In the Stacks


The Supreme Court’s Federal Tax Jurisprudence, Second Edition

The Second Edition of The Supreme Court’s Federal Tax Jurisprudence comes at a time when Congress is pushing the tax law into new and uncharted territory while we all hold out hope for the fundamental reform of the Internal Revenue Code that is long overdue. This review was originally published as the Foreword in The Supreme Court’s Federal Tax Jurisprudence, Second Edition.

Young Lawyers Corner

Tax Bits

Let's Confer


Report on the 33rd Annual National Institute on Criminal Tax Fraud and the Sixth Annual National Institute on Tax Controversy

This conference—now in its thirty-third year as the National Institute on Criminal Tax Fraud, and its sixth year since combining with the National Institute on Tax Controversy—brings together tax practitioners, judges, and representatives from the IRS and the Department of Justice for three days of workshops and programming topics related to tax controversy, tax litigation, and criminal tax prosecution and defense.

News & Announcements

Events & Promotions

Sponsor Acknowledgements

About ABA Tax Times

ABA Tax Times (ISSN 2381-5868) (formerly NewsQuarterly) reports on developments pertaining to taxation, Tax Section news and meeting updates, and other information of professional interest to Tax Section members and other readers. Questions regarding ABA Tax Times can be sent to: [email protected].

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