A “tax opinion” is a formal, written statement provided by a lawyer to a client about the tax consequences of a specific transaction. In addition to describing the expected tax treatment, the opinion also specifies the lawyer’s confidence in this determination—a “will” opinion indicates near certainty; a “more likely than not” opinion is much more… Continue reading →
Much has been said about the new $10,000 cap on the federal deduction for payments of state and local taxes (“SALT”), but the commentary generally focuses on the state-level impacts and responses. My colleague Manoj Viswanathan, in his recent essay, “Hyperlocal Responses to the SALT Deduction Limitation,” published in the Stanford Law Review Online, argues that this… Continue reading →
Who matters in the tax-policy debate? My colleague, Leo Martinez, in his recent article Latinos and the Internal Revenue Code: A Tax Policy Primer for the New Administration, 20 Harv. Latinx L. Rev. 101 (2017), argues that legislators and policymakers should pay more attention to Latinos and how they are adversely affected by the tax law. To… Continue reading →
Law school clinics have long served students interested in litigation. And the past decade has brought a dramatic increase in the number of transactional-law clinics at law schools across the country, which is clearly a positive development for the many law students who are interested in business/transactional work. But what about students interested in transactional… Continue reading →
Politicians, pundits, and countless others indiscriminately describe disfavored provisions as “tax loopholes.” Yet as my colleague and fellow tax scholar Professor Heather Field demonstrates in her recently published article, A Taxonomy for Tax Loopholes, the term lacks definitional clarity. The phrase has been used, variously, to reference statutory ambiguities, violations of the spirit of the… Continue reading →
My colleague Manoj Viswanathan has written a new article, “Tax Compliance in a Decentralizing Economy,” forthcoming in Georgia State University Law Review. This article reveals the threat to tax compliance that is posed both by new technologies that enable on-demand sharing of services and by blockchain technology that facilitates cryptocurrency (e.g., Bitcoin) transactions and other… Continue reading →
Heather Field, my colleague and fellow tax scholar, has written two important articles at the intersection of the practice of tax law and professional ethics. There are scant resources for (1) tax practitioners seeking guidance on how to act ethically when making discretionary decisions involving aggressive tax planning and (2) tax law faculty who want… Continue reading →
