In Memoriam: Steven C. Salch Paul J. Sax Sharing a passion with Steve Salch was an easy thing. When he cared about something you knew it. He commanded your attention and was relentless about it, drawing you into the vortex that was Steve. ...
2010 Erwin N. Griswold Lecture Before the American College of Tax Counsel: Taking the Bull by Its Horns: Some Thoughts on Constitutional Due Process in Tax Collection Nina E. Olson I am honored to be here tonight, and to have been asked to deliver the Griswold Lecture, a lecture that is really remarkable in that its past presenters are at the pinnacle of thinking deeply about tax. ...
The Regulatory Systems for Employee Benefits Brian A. Benko In 2000, the late Michael S. Gordon, who has been hailed as one of the architects of the Employee Retirement Income Security Act of 1974, wrote a piece entitled ERISA in the 21st Century. ...
Premium Financed Surprises: Cancellation of Indebtedness Income and Financed Life Insurance Robert S. Bloink In today’s dismal credit markets, concerns regarding cancellation of indebtedness income are being raised as billions of dollars worth of life insurance premiums financed over the past five years are coming home to roost. ...
The Option Conundrum in Tax Law: After All These Years, What Exactly Is an Option? Kevin J. Liss An option is typically described as a contract between two parties that provides one party the right, but not the obligation, to buy or sell an underlying property at a set price and date. ...
Taxation and the Sabbatical: Doctrine, Planning, and Policy John A. Miller and Robert Pikowsky Many universities offer faculty the opportunity to apply for a form of paid leave known as a sabbatical. This is one of the most highly prized perquisites of the academic profession because it offers an unrivaled opportunity...
Beating the Dead Horse: Revisiting McDougal in Search of Substantial Authority Rodney P. Mock Over thirty-five years have passed (including a certain racehorse named “Iron Card”) since the famous U.S. Tax Court case of McDougal v. Commissioner, yet to this day taxpayers in partnerships, tax practitioners, and academics...
The Application of Conduit Theory in Interest Rate Swap Transactions: Schering-Plough Corporation v. United States Sally Bergmann In Schering-Plough Corporation v. United States, the District Court for the District of New Jersey concluded that lump-sum payments by a foreign subsidiary to its parent corporation in exchange for the right...
A Gift to be Returned: Single-Member LLCs and Gift Tax Valuation in Pierre v. Commissioner Bradley Sarnell On August 24, 2009, the United States Tax Court gave an unexpected gift to taxpayers, holding that a gift of an interest in a disregarded, single-member limited liability corporation should be valued...
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