Vol. 75, No. 3 - Spring 2022

Articles

Taxation

Tax Opinion Policies and Procedures

by Linda Galler

This Article summarizes and comments on a 2021 survey by the American College of Tax Counsel (ACTC) on the policies and procedures followed by law and accounting firms in drafting tax opinions. The Article provides background on the contexts...

Taxation

Exchange-Traded Funds Use Section 852(b)(6) for Tax Avoidance, Not Just Tax Deferral: So Why Is This Loophole Still Open?

by Steven Z. Hodaszy

Exchange-traded funds (ETFs) exploit section 852(b)(6) of the Internal Revenue Code to avoid taxation of their realized investment gains at either the entity level or the shareholder level. The provision prevents a regulated investment company...

State and Local Tax

Taxation

U.S. State Taxation of Cryptocurrency- Involved Transactions: Trends and Considerations for Policy Makers

by Casey W. Baker, Thomas Norton, and Ralph E. McKinney

This Article examines legal doctrines relating to state-level taxation of cryptocurrency-involved commercial transactions in the United States, including constitutional limitations and current state approaches to income, sales and use...

The Tax Lawyer

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Vol. 75, No. 3 - Spring 2022

The Tax Lawyer, Spring 2022

Articles

Tax Opinion Policies and Procedures

Exchange-Traded Funds Use Section 852(b)(6) for Tax Avoidance, Not Just Tax Deferral: So Why Is This Loophole Still Open?

State and Local Tax

U.S. State Taxation of Cryptocurrency- Involved Transactions: Trends and Considerations for Policy Makers

The Tax Lawyer

Subscribing

ABA Resources

The ABA

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Renew Your ABA Membership

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Vol. 75, No. 3 - Spring 2022

The Tax Lawyer, Spring 2022

Articles

Tax Opinion Policies and Procedures

Exchange-Traded Funds Use Section 852(b)(6) for Tax Avoidance, Not Just Tax Deferral: So Why Is This Loophole Still Open?

State and Local Tax

U.S. State Taxation of Cryptocurrency- Involved Transactions: Trends and Considerations for Policy Makers

The Tax Lawyer

Subscribing

ABA Resources

The ABA

Connect