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.
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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
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
Comments on the Tax Treatment of Hard Forks
American Bar Association Section of Taxation
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, 2018
American Bar Association Section of Taxation
Comments on the 2014 Offshore Voluntary Disclosure Program and the Streamlined Procedures
American Bar Association Section of Taxation
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
Comments Concerning H.R. 5444 “Taxpayer First Act”
American Bar Association Section of Taxation
Memorandum of Agreement dated April 11, 2018, and Review of Tax Regulations Under Executive Order 12866
American Bar Association Section of Taxation
ARTICLES
Section 355 Revisited: Time for a Major Overhaul?
Herbert N. Beller
Abstract
More of the “Same”: Section 6621(d) in the Federal Circuit
David Berke
Abstract
Section 4960: Unpleasant Surprises and Unanswered Questions for Tax-Exempt Entities with 457 Plans
Brian Gallagher
Abstract
OECD BEPS (In)Action 1: Factor Presence as a Solution to Tax Issues of the Digital Economy
Monica Gianni
Abstract
The Section 871(m) Qualified Index Rules
Jeffrey D. Hochberg
Abstract
A Model of Complexity and Uncertainty: Redemptions of Partnership Interests
Michelle M. Jewett
Abstract
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