Volume 71, No. 2 - Winter 2018

Reports

Comments on Proposed Regulations Implementing the Partnership Audit Procedures Enacted as Part of the Bipartisan Budget Act of 2015

ABA Section of Taxation

The Bipartisan Budget Act of 2015 (as modified by the Protecting Americans from Tax Hikes Act of 2015) adopted a new centralized regime through which the Internal Revenue Service will audit partnerships. ...

Comments Regarding Capital Accounts and Basis with Respect to Proposed Regulations Implementing the Partnership Audit Procedures Enacted as Part of the Bipartisan Budget Act of 2015

ABA Section of Taxation

The Bipartisan Budget Act of 2015 (as modified by the Protecting Americans from Tax Hikes Act of 2015 (the “PATH Act”) adopted a new centralized regime through which the Internal Revenue Service will audit partnerships. ...

Comments on Draft Revenue Procedure Addressing Issues Under Section 1362(f)

ABA Section of Taxation

For many corporations and shareholders, an election to be treated as an S corporation is a valuable tax-planning tool, as it allows the income of the corporation to be taxed at just one level...

Articles

United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?

Caroline Rule

In 1976, in Fisher v. United States, the Supreme Court first recognized the “act of production privilege” as being a necessary component of the Fifth Amendment’s privilege against self-incrimination. ...

Do Tax-Motivated Wash Gain Sales Pass Economic Substance Muster?

Stanley Veliotis

For nearly a century, the Code has disallowed wash losses, which are losses from the sale of a share of stock or other security for which the taxpayer within 30 days before or after the sale repurchases the asset. ...

The Tax Lawyer

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Vol. 71, No. 2 - Winter 2018

The Tax Lawyer, Winter 2018

Reports

Comments on Proposed Regulations Implementing the Partnership Audit Procedures Enacted as Part of the Bipartisan Budget Act of 2015

Comments Regarding Capital Accounts and Basis with Respect to Proposed Regulations Implementing the Partnership Audit Procedures Enacted as Part of the Bipartisan Budget Act of 2015

Comments on Draft Revenue Procedure Addressing Issues Under Section 1362(f)

Articles

United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?

Do Tax-Motivated Wash Gain Sales Pass Economic Substance Muster?

The Tax Lawyer

Now Available: The Tax Lawyer Audio Edition from ModioLegal

Subscribing

American Bar Association TM American Bar Association

Vol. 71, No. 2 - Winter 2018

The Tax Lawyer, Winter 2018

Reports

Comments on Proposed Regulations Implementing the Partnership Audit Procedures Enacted as Part of the Bipartisan Budget Act of 2015

Comments Regarding Capital Accounts and Basis with Respect to Proposed Regulations Implementing the Partnership Audit Procedures Enacted as Part of the Bipartisan Budget Act of 2015

Comments on Draft Revenue Procedure Addressing Issues Under Section 1362(f)

Articles

United States v. Greenfield: A Triumph of the Fifth Amendment’s Act of Production Privilege; or Confirmation that the Privilege Can Be Entirely Abrogated by Any Act of Congress, or Even by a Treasury Regulation?

Do Tax-Motivated Wash Gain Sales Pass Economic Substance Muster?

The Tax Lawyer

Now Available: The Tax Lawyer Audio Edition from ModioLegal

Subscribing