After many proposed and temporary regulations and recent legislative changes, major portions of the new anti-tax shelter rules are now final. Although targeted at abuses, the regime is broad and can unexpectedly impact lawyers and accountants involved in common business transactions. This...

This article examines the alternative forms available to merging tax partnerships and reveals how the different forms can affect the tax consequences of the parties to such a transaction. In particular, the article illustrates how parties should choose the proper form as needed to avoid adverse...