Vol. 72, No. 1 - Fall 2018

 

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Vol. 72, No. 1 (Fall 2018)

CONTENTS

REPORTS

Recommendations for the 2018-2019 Department of the Treasury and Internal Revenue Service Priority Guidance Plan Related to the Act
American Bar Association Section of Taxation
Full Article

Second Set of Recommendations for the 2018-2019 Department of the Treasury and Internal Revenue Service Priority Guidance Plan
American Bar Association Section of Taxation
Full Article

Comments on the Tax Treatment of Hard Forks
American Bar Association Section of Taxation
Full Article

Comments on Sections 864(c)(8) and 1446(f ) as Added to the Internal Revenue Code of 1986 by P.L. 115-97 on December 22, 2017
American Bar Association Section of Taxation
Full Article

Comments on the 2014 Offshore Voluntary Disclosure Program and the Streamlined Procedures
American Bar Association Section of Taxation
Full Article

Comments on Notice 2017-73, Request for Comments on Application of Excise Taxes with Respect to Donor Advised Funds in Certain Situations
American Bar Association Section of Taxation
Full Article

Comments Concerning H.R. 5444 “Taxpayer First Act”
American Bar Association Section of Taxation
Full Article

Memorandum of Agreement Dated April 11, 2018, and Review of Tax Regulations Under Executive Order 12866
American Bar Association Section of Taxation
Full Article

ARTICLES

Section 355 Revisited: Time for a Major Overhaul?
Herbert N. Beller
Full Article   |   Abstract

More of the “Same”: Section 6621(d) in the Federal Circuit
David Berke
Full Article   |   Abstract

Section 4960: Unpleasant Surprises and Unanswered Questions for Tax-Exempt Entities with 457 Plans
Brian Gallagher
Full Article   |   Abstract

OECD BEPS (In)Action 1: Factor Presence as a Solution to Tax Issues of the Digital Economy
Monica Gianni
Full Article   |   Abstract

Fast-Pay Stock
Jeffrey D. Hochberg
Full Article   |   Abstract

A Model of Complexity and Uncertainty: Redemptions of Partnership Interests
Michelle M. Jewett
Full Article   |   Abstract

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