Tax Opinion Policies and Procedures
This Article summarizes and comments on a 2021 survey by the American College of Tax Counsel (ACTC) on the policies and procedures followed by law and accounting firms in drafting tax opinions.
The Tax Lawyer | Spring 2022
Volume 75, Issue 3
Articles
Exchange-Traded Funds Use Section 852(b)(6) for Tax Avoidance, Not Just Tax Deferral: So Why Is This Loophole Still Open?
Exchange-traded funds (ETFs) exploit section 852(b)(6) of the InternalRevenue Code to avoid taxation of their realized investment gains at eitherthe entity level or the shareholder level.
U.S. State Taxation of Cryptocurrency- Involved Transactions: Trends and Considerations for Policy Makers
This Article examines legal doctrines relating to state-level taxation of cryptocurrency-involved commercial transactions in the United States, includingconstitutional limitations and current state a…