Tax Flotsam of Partnership Mergers and Divisions
This Article addresses the technical aspects of partnership mergers and divisions. The Article will be an invaluable resource for taxpayers and their advisors who must be aware of the tax issues and…
The Tax Lawyer | Spring 2024
Volume 77, Issue 3
Articles
Navigating the Split-Holding-Period Rules for Partnership Interests
Review of the split-holding-period rules in Regulation section 1.1223-3, to make sense out of the confusion they often cause. Article proposes specific textual revisions to Reg. section 1.1223-3, eli…
Charity Law & Blockchain Technology: Using Old Wineskins for New Wine?
How existing charity law applies to these new assets and, to the extent that application is either uncertain or inconsistent with the policy goals underlying charity law, how charity law should be mo…
Tax Scholars and the Courts: Applying the APA to Tax Since Mayo
No exceptions from the Administrative Procedure Act for tax, judges and scholars have debated the application of administrative law to the field of tax. Article lays out the existing debate among jud…
The Future of SALT(?): Using and Improving Formulas for Apportioning Income, Residence and Intangibles
These formulas can and should be improved. Improvement does not require the introduction of the faux rigor of transfer pricing. Argues for extending the use of formulas to areas of state and local ta…