Volume 74, Issue 3
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 u…
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 marriagewithin the LGBTQ+ community. ...
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. ...
The death of a tax partnership has recently taken on increased importance.Under the centralized partnership audit regime enacted as part of the BipartisanBudget Act of 2015 (the BBA), whether a partn…
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. ...
My topic today focuses broadly on tax education and, more specifically,upon the important role of tax practitioners as teachers of law school taxcourses. ...