President Obama is faced with a national debt at over $11 trillion and needs to fund projects such as National Health Care with an ever shrinking tax base. As the economy has slowed, so have tax revenues. It would then make sense for the government to re-examine tax carve outs which only benefit...

The global economic crisis caused residential home prices in the United States to plummet from 2006-2010. This, combined with a relatively weak U.S. currency, created a perfect storm for foreign investors to enter the U.S. residential real estate market. Foreign investors need to be educated by...

Same-sex couple rights are the topic of much discussion and debate. There are court challenges to the constitutionality of the Defense of Marriage Act (“DOMA”) as well as proposed marriage statutes. The message and the structure for the recognition of same-sex rights need to be modified....

The economic downturn has created an investment market in which some tax-advantaged strategies have become favored. To avoid taxable diversification, taxpayers have turned to exchange funds. Through the rules in sections 351, 721, and 368, taxpayers can diversify a single stock position without...

The ability of the Internal Revenue Service (IRS) to both collect the tax and enforce the initial determination of tax liability in a neutral and fair manner has been compromised by a February 2011 pronouncement issued by the Department of Justice (“Justice”) stating that the President and...

The ability of the Internal Revenue Service to both collect the tax and enforce the initial determination of tax liability in a neutral and fair manner has been compromised by a February 2011 pronouncement issued by the Department of Justice stating that the President and the Department of...

The estate tax and income tax rules independently attempt to either promote or deter different behaviors. The interaction of these different rules often leads to disparate or unintended consequences to taxpayers: for example, achieving an overall lower effective tax rate by paying more estate...

In order to have optimal tax compliance in the field of tax reporting, under our current paradigm, we need clearly articulated but salient standards for record keeping. The popular belief that taxpayers do not need to keep adequate records creates a behavior distortion of noncompliance. This...