In Memoriam: Phillip L. Mann Paul J. Sax and Lawrence B. Gibbs Lurking beneath his radiant warmth and unparalleled affability was a near unique combination. Those who didn’t know Phil Mann might have trouble understanding that he was both a committed idealist...
“Time Present and Time Past:” U.S. Anti-Treaty Shopping History, Policy, and Rules J. Ross Macdonald This Article comprehensively discusses U.S. anti-treaty shopping (limitation on benefits) rules contained in U.S. income tax treaties up to and including the rules contained in the 2016 U.S. Model Treaty. ...
The Legal Consequences of Noncompliance with Federal Tax Laws Allen D. Madison This Article addresses the legal consequences a taxpayer should consider when deciding whether to comply with the basic requirements of the federal income tax laws. ...
On the Use and Abuse of Legislative History in the “Preparer Fraud” Doctrine Adam S. Wallwork For more than a century, U.S. tax evaders have been liable for unpaid tax at any time so that statutes of limitation do not stymie collection of fruits of fraud. Today, however, federal courts of appeal are split...
The Tax Lawyer The Tax Lawyer, the nation’s premier, peer-reviewed tax law journal, is published quarterly as a service to its members by the American Bar Association Section of Taxation. Abstracts can be viewed by anyone, but full text pdfs are accessible only to members of the Section. Section members may also view the Spring 2018 issue of The Tax Lawyer in its entirety.
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