Vol. 70, No. 3 - Spring 2017

2017 Erwin N. Griswold Lecture Before the American College of Tax Counsel: A (Not So) Modest Proposal

Karen L. Hawkins

Reviewing the list of honorees and previous Griswold Lectures is a truly humbling and intimidating exercise. I am honored, albeit stunned, to be speaking to you all this evening. ...

Comments on Proposed Regulations Under Section 751(b)

ABA Section of Taxation

Section 751(b) applies to a distribution of property from a partnership to a partner if the effect of the distribution is to effect an exchange of the distributee’s share of unrealized receivables...

Taxation

Hot Asset Exchanges: Integrating Sections 704(c), 734(b), and 751(b)

Karen C. Burke

Long-awaited proposed regulations would revise the operation of section 751(b) to reflect modern concepts of partnership taxation. ...

Taxation

Proceed with Caution: D(e)riving a Hybrid Down the Tax Treaty On-Ramp

Andrew Walker

Double tax treaties are bilateral sovereign agreements by which countries agree to reduce taxes that they would otherwise impose on residents of the other country in exchange for reciprocal relief for their own residents. ...

Out of Bounds: How Garcia v. Commissioner Illustrates the Impossibility of Applying the Rules of Taxation Affecting Nonresident Alien Athletes

Jay L. Tymkovich

Like lining up a double-breaking 50-foot putt, computing one’s taxes is an inherently complicated and daunting task. Accordingly, one would expect that the Service would try to add simplicity...

Kuretski v. Commissioner: The Tax Court’s Identity Crisis

Spencer P. Williams

In the complex and highly technical world of tax law, the Tax Court plays a vital role in hearing pre-assessment challenges to tax deficiency claims. ...