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Issue Date:
03/22/2007
In This Issue
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1-10 (of 14) related articles
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1. Tax Shelters and the Code
The recent tendency of courts to apply the rule of lenity in civil cases potentially leads to a narrow interpretation of the Internal Revenue Code. (PERIODICAL ARTICLE)
2. In Defense of Tax Shelters
Tax shelters do not have many defenders. The lawyers who have to defend them on behalf of a client tend to simply appeal to the ... (PERIODICAL ARTICLE)
3. In defense of requiring back-flips.
In his article, In Defense of Tax Shelters, (1) Leo Katz lives up to his usual standard of being iconoclastic, provocative, illuminating, and fun ... (PERIODICAL ARTICLE)
4. Compaq redux: implicit taxes and the question of
pre-tax profit.
I. INTRODUCTION Until recently, (1) more ink was probably spilled over the cross-border, dividend-stripping transactions in Compaq v. Commissioner (2) and IES Industries v. (PERIODICAL ARTICLE)
5. Tax shelters, Dutch books, and the fundamental theorem
of asset pricing.
Because the tax law makes many distinctions not based on fundamental economic differences, taxpayers can exploit these inconsistencies to create opportunities for tax arbitrage. (PERIODICAL ARTICLE)
6. Of lenity, Chevron, and KPMG.
I. INTRODUCTION Despite a mixed track record in challenging tax shelters in civil enforcement actions, the federal government has started prosecuting tax shelter cases ... (PERIODICAL ARTICLE)
7. Creating failures in the market for tax
planning.
I. INTRODUCTION Although most people recognize the necessity of taxes, few people like to pay them. Governments expend costs to collect taxes; people expend ... (PERIODICAL ARTICLE)
8. Disrupting the market for tax
planning.
I. INTRODUCTION It is a pleasure to comment on Philip Curry, Claire Hill, and Francesco Parisi's article (1) on creating market failures for tax ... (PERIODICAL ARTICLE)
9. Patents, tax shelters, and the
firm.
I. INTRODUCTION The United States patent statute offers exclusive rights in any new and useful "process, machine, manufacture, composition of matter" or new and ... (PERIODICAL ARTICLE)
10. Questioning the wisdom of patent protection for tax
planning.
I. INTRODUCTION The topic of federal patent protection for tax planning strategies has received considerable attention of late, (1) much of it from a ... (PERIODICAL ARTICLE) | |
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1-10 (of 14) related articles
Items per page
1-10 (of 14) related articles
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