Vol. 74, No. 3 - Spring 2021

Articles

Taxation

“Partnership Revaluations: Book-Ups Are Your Friends (Usually)”— Planning with Revaluations and Their Interplay with Section 704(c)

by Daniel S. Goldberg

The procedure provided in the section 704(b) regulations known as “revaluation and book-up” (sometimes called simply “book-up”) of a partnership’s assets and capital accounts is available and often used when a new partner enters an existing...

Taxation

Hegemonic Marriage: The Collision of “Transformative” Same-Sex Marriage with Reactionary Tax Law

by Anthony C. Infanti

Before there was a culture war in the United States over same-sex marriage, there was a battle between opponents and proponents of same-sex marriage within the LGBTQ+ community. ...

Taxation

Recovery for Causing Tax Overpayment— Lyeth v. Hoey and Clark Revisited

by Douglas A. Kahn and Jeffrey H. Kahn

The question has arisen in numerous cases as to the extent to which a settlement between arm’s length parties is dispositive in tax cases of the claims on which the settlement is based. ...

Taxation

When Does a BBA Partnership Terminate?

by Andrew L. Lawson

The death of a tax partnership has recently taken on increased importance. Under the centralized partnership audit regime enacted as part of the Bipartisan Budget Act of 2015 (the BBA), whether a partnership “ceases to exist” can change...

Taxation

The Tax Guide to Offshore Lending

by David S. Miller

The Article explains the various structures that permit offshore funds with U.S. managers to originate loans without the fund or its investors being subject to any meaningful amount of U.S. tax. ...

Taxation

2021 Erwin N. Griswold Lecture Before the American College of Tax Counsel: Tax Lawyers as Teachers—A Precious Commodity

Herbert N. Beller

My topic today focuses broadly on tax education and, more specifically, upon the important role of tax practitioners as teachers of law school tax courses. ...

The Tax Lawyer

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Vol. 74, No. 3 - Spring 2021

The Tax Lawyer, Spring 2021

Articles

“Partnership Revaluations: Book-Ups Are Your Friends (Usually)”— Planning with Revaluations and Their Interplay with Section 704(c)

Hegemonic Marriage: The Collision of “Transformative” Same-Sex Marriage with Reactionary Tax Law

Recovery for Causing Tax Overpayment— Lyeth v. Hoey and Clark Revisited

When Does a BBA Partnership Terminate?

The Tax Guide to Offshore Lending

2021 Erwin N. Griswold Lecture Before the American College of Tax Counsel: Tax Lawyers as Teachers—A Precious Commodity

The Tax Lawyer

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Renew Your ABA Membership

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Vol. 74, No. 3 - Spring 2021

The Tax Lawyer, Spring 2021

Articles

“Partnership Revaluations: Book-Ups Are Your Friends (Usually)”— Planning with Revaluations and Their Interplay with Section 704(c)

Hegemonic Marriage: The Collision of “Transformative” Same-Sex Marriage with Reactionary Tax Law

Recovery for Causing Tax Overpayment— Lyeth v. Hoey and Clark Revisited

When Does a BBA Partnership Terminate?

The Tax Guide to Offshore Lending

2021 Erwin N. Griswold Lecture Before the American College of Tax Counsel: Tax Lawyers as Teachers—A Precious Commodity

The Tax Lawyer

Subscribing

ABA Resources

The ABA

Connect