Alumnus Bob Kane, publishes QSub Dispositions: Example 9 and Nonrecognition Transactions in Tax Notes

Bob Kane, a JD and Tax LLM alumn recently published an article in Tax Notes that examines whether Example 9 of reg. section 1.1361-5(b)(3) governs the disposition of a qualified subchapter S subsidiary in a nonrecognition transaction. Bob served as a Tax Court clerk for the U.S. Tax Court from 2012 to 2014. Now, at Ropes … Read more

Citizenship Overreach

Peter Spiro, Citizenship Overreach, 38 Mich. J. Int’l L. 167 (2017). This article examines international law limitations on the ascription of citizenship in the context of U.S. taxation of non-resident citizens. U.S. citizenship practice is exceptionally generous, extending citizenship to almost all persons in its territory at the moment of birth. At the same time that it is … Read more

Tax: Different Not Exceptional

Alice G. Abreu and Richard K. Greenstein, Tax: Different Not Exceptional, 71 Adm. L. Rev. **(Forthcoming 2019). This article examines the concept of tax exceptionalism–the idea that tax law is fundamentally different from other fields of law and perhaps isn’t law at all. It explores the reasons tax has been thought to be exceptional but … Read more

Embracing the TBOR

Alice G. Abreu and Richard K. Greenstein, Embracing the TBOR, 157 Tax Notes 1281 (2017).  This article develops three arguments is support of the proposition that the Taxpayer Bill of Rights, enacted in 2015 as part of the Internal Revenue Code, is not a mere cosmetic but has the potential to transform tax administration.

What We Talk About When We Talk About Tax Complexity

Andrea Monroe, What We Talk About When We Talk About Tax Complexity, 5 Mich. Bus. & Entrepreneurial L. Rev.193 (2017). This essay offers some preliminary evidence of the pervasive influence of legal craft values in partnership taxation. Legal craft values shape our perception of the law, and they shape the law itself, orienting subchapter K toward … Read more