ABSTRACT Internal Revenue Service (IRS) publications are everywhere in tax practice and
almost nowhere in tax scholarship. These publications seek to explain substantive tax law to …

The “tax gap”—the difference between the amount of “true tax” and the amount of tax
actually paid—has garnered widespread attention in recent months. Much of the …

There is a growing awareness that federal tax law caters to a small number of wealthy and
well-advised taxpayers without regard for the rest of the taxpaying public, and partnership …

Partnerships (including LLCs) account for more than one-third of US business profits. A key
feature they offer owners and investors is unparalleled flexibility to divide up income and …

Abstract Recently, an inadvertent Internal Revenue Service disclosure revealed a tax
controversy involving Bristol-Myers Squibb's contribution of zero-basis, high-value …

US partnerships control more than $40 trillion in assets, vastly outnumber US public firms,
and contribute significantly to the US tax non-compliance of pass-through entities, which is …

Publicly traded entities are generally treated as corporations for US tax purposes. Under
various exceptions, however, publicly traded entities may obtain special treatment if they …

Section 704 (b) and its Regulations allows partnerships a great deal of flexibility on how
items of income and deduction are allocated to partners. This flexibility has been heavily …

Zusammenfassung Die steuerliche Anerkennung von Gewinnverteilungsabreden in
Personengesellschaften ist von wissenschaftlichem Interesse wie von praktischer …

In less than a decade, the term" cryptocurrency" has astonishingly evolved from a
sophisticated term used by technologists or crypto-enthusiasts, to becoming a mainstream …