Tax Notes Federal and Tax Notes Today Federal: Compendium of Letters to the Editor
This is a collection of links to letters to the editor of Tax Notes Federal that I have written over the past decade and a half. They cover all sorts of issues involving many different areas of tax law. The links are behind the Tax Analysts’ paywall and ALMOST ALL OF THEM were published on my SSRN page.
I. Not On SSRN Page
1. Aggregate-Entity Redux
5/8/2023
2. Tax Credit Transfer Proposed Regulations Leave Some Questions
6/26/ 2023
3. Will Moore Upend Subchapter K?
7/10/2023
4. We Need Subchapter K Reform
8/7/2023
5. The ALI Centennial and the Future of Tax Projects
8/28/2023
6. Hiring More Agents: A Good Start but Not the Sole Solution
9/25/2023
7. Systemic Failure at the IRS and Treasury?
10/23/2023
8. Don’t Forget Liabilities in Excess of Basis at Death
1/29/2024
II. On SSRN Page
1. Statutory Conflicts, Interpretation Animate Recent IRS Guidance
3/20/2023
2. Revise IRS-Treasury Business Plan Process
|2/27/2023
3. Litigation Is Not the Way to Go
|2/20/2023
4. Grecian Magnesite and Its Offspring: Is Rawat Correct?
|2/13/2023
5. It’s Time to Reconsider Wyden’s Partnership Tax Reforms
|1/16/2023
6. Conservation Easement Proposal Becomes Law
|1/2/2023
7. Of Nonrecognition Transactions and Financial Statement Income
|10/31/2022
8. IRS Failure to Enforce the Partnership Tax Law: A Serious Breach?
|10/10/2022
9. Who Is a Partner Under the Inflation Reduction Act of 2022?
|9/5/2022
10. Book Corporate Income Tax in Partnership Land
|8/22/2022
11. The Carried Interest Proposal in the Inflation Reduction Act
|8/1/2022
12. Partnerships’ Charity Contributions in Kind Need Reform
|6/27/2022
13. Some Still-Troubling Issues Under the BBA
|5/16/2022
14. An Annual Tax on Billionaires Needs No Step-Up in Basis at Death
|4/18/2022
15. The Green Book Has Some Serious Flaws
|4/4/2022
16. When Is Gain Recognized Subject to Tax for Foreign Partners?
|2/14/2022
17. The New PFIC Regs’ Aggregate Approach Makes No Sense
|1/31/2022
18. Collection of Value-Depleting Royalties May Not Be a Sale
|1/24/2022
19. Proposals for Limited Subchapter K Reform in Reconciliation Bill
|11/1/2021
20. Wyden Partnership Proposals Should Become Law
|10/25/2021
21. The Way to Challenge Tax Rules Remains Unresolved
|5/24/2021
22. Unlikely U.S. Implementation of OECD Initiatives Raises Questions
|5/3/2021
23. The Corporate Transparency Act Should Cover Indirect Ownership
|2/15/2021
|1/25/2021
25. Potential Danger of Making Public Pre-Release Versions of Regulations
|1/11/2021
26. Phantom Regulations Under the APA
|1/4/2021
27. Conservation Easement Bill Does Not Jibe With Partnerships
|12/14/2020
28. SALT Workaround Notice Works Politically but Not Legally
|11/16/2020
29. A Principal Purpose: 194 Entries and Counting
|11/2/2020
30. Saying Anything That Gets the IRS the Answer It Wants
|10/5/2020
31. Of Legislative History and Regulation Preambles
|9/28/2020
32. The Future of Carried Interest Legislation and Regulations
|8/24/2020
33. Deemed Sales Arise on Change in Grantor Trust Ownership
|6/15/2020
34. Retroactive Tax Laws and Penalties
|5/25/2020
35. Government Is Not a Person Under the Code: What Is the Secret?
|5/4/2020
36. Practitioner Responds to Debate Over PTP Ruling
|4/27/2020
37. Letter Ruling on PTP Look-Through Is Illegal
|4/21/2020
38. The IRS Defining ‘Tax Basis Capital’ in FAQs Is Inappropriate
|11/18/2019
39. How to Read the Code, Regs, and Rulings: A Response to Willens
|11/4/2019
40. Death Remains a Disposition
|10/21/2019
41. LIBOR Transition Regs and Effective Date Issues
|10/14/2019
42. Guidance Is Needed on the Codified Economic Substance Doctrine
|10/7/2019
43. Treasury Guidance Policy Statement Redux
|9/23/2019
44. IRS Lacks the Authority to Index Capital Gains to Inflation
|8/12/2019
45. Proving That the Partnership Antiabuse Reg Has No Place
|5/14/2018
46. Carried Interest Repeal Is Not So Simple
|5/15/2017
47. The Latest Presidential Executive Order on Tax Regulations
|5/1/2017
48. Border Adjustability and Subchapter K
|2/27/2017
49. Simplify the Partnership Audit Rules
|5/23/2016
50. Partnership Audit Rules: Taxing at the Partner Level
|5/2/2016
51. Sun Capital Could Have Implications Beyond ERISA
|4/25/2016
52. Technical Flaw in Anti-Loss Importation Regs
|4/4/2016
53. Practitioner Calls for Clarifying Election Out Rules
|11/30/2015
54. Does Economic Substance Doctrine Apply to Partnership Allocation?
|11/9/2015
55. A Case of Careless Drafting?
|9/14/2015
|7/20/2015
57. Exculpatory Liability Issue Must Be Addressed, Practitioner Says
|6/29/2015
58. ILM Analysis of Barrier Option Transaction Incomplete
|6/1/2015
59. Practitioner Finds Vicious Cycle at IRS With Subchapter K
|5/18/2015
60. Better Think Twice About Partnership Tax Changes
|4/13/2015
61. Reforming Passthrough Entity Taxation
|3/23/2015
62. Apply Economic Substance More Vigorously, Practitioner Advises
|3/9/2015
63. PCAOB Tax Transaction Rule Review: Proceed With Caution
|12/8/2014
64. Potential Concerns With Auditing Large Partnerships
|11/17/2014
65. A Failure of Policy or Just Creative Tax Rulemaking?
|11/10/2014
66. Camp Tax Reform Plan: Not Enough for Partnerships?
|3/10/2014
67. Criticize the Regs, Not the Authors
|2/10/2014
68. A Personal Perspective on the Tax Lawyer Opinion Debate
|1/20/2014
69. Public Comments vs. Private Letter Rulings: Which Is Preferable?|9/27/2010
70. Response to Anonymous Letter to the Editor
|8/16/2010
71. Jackel Urges Tax Professionals to Comment on Economic Substance Codification
|6/15/2010
