Paul Daugerdas gained notoriety for himself and his erstwhile firm, Jenkens & Gilchrist, as the designer of a tax shelter that uses contingent liabilities to generate artificial tax losses on a grand scale. The basic shelter transaction is surprisingly simple. In essence, it uses offsetting options to inflate the basis of property that is distributed by a partnership and then contributed to and sold by another partnership, resulting in a large tax loss without any corresponding economic loss. In principle, this type of shelter could be replicated indefinitely and generate unlimited tax losses. Mr. Daugerdas is by no means unique. The transactions that he approved as shelter counsel on behalf of Jenkens & Gilchrist differ only in trivial det...
There continues to be heated discussion about tax reform in the area of real estate tax shelters. In...
The main question this article will discuss is whether the inability of a client to rely on a client...
This Article considers the role of tax lawyers in the corporate tax shelter controversy. In the mid-...
Paul Daugerdas gained notoriety for himself and his erstwhile firm, Jenkens & Gilchrist, as the desi...
This article describes the ongoing legislative and administrative efforts to curtail tax shelters. I...
During the past decade, tax shelter investments were among the most controversial planning devices u...
In the 1990’s and early 2000’s the tax landscape in the United States was overrun by an epidemic of ...
This is Chapter 1 of Confidence Games (MIT, 2014). Confidence Games provides an account of the wave ...
Tax shelters, once thought to be extinct due to the at-risk and passive activity loss rules, continu...
This Comment will examine the history of nonrecourse financing and tax shelters from the fabled Cran...
During 1976, Congress placed some severe restrictions on tax shelter investments. In addition, even ...
Tax shelters have evoked an abundance of journalistic speculation, expertcommentary and legislative ...
After briefly reviewing the so-called abusive aspects of tax shelters which led Congress to enact th...
Tax shelters have proliferates in the United States not only because of financial innovation, the gl...
The Tax Reform Act of 1976 made sweeping changes in the area of tax shelters. Real estate tax shelte...
There continues to be heated discussion about tax reform in the area of real estate tax shelters. In...
The main question this article will discuss is whether the inability of a client to rely on a client...
This Article considers the role of tax lawyers in the corporate tax shelter controversy. In the mid-...
Paul Daugerdas gained notoriety for himself and his erstwhile firm, Jenkens & Gilchrist, as the desi...
This article describes the ongoing legislative and administrative efforts to curtail tax shelters. I...
During the past decade, tax shelter investments were among the most controversial planning devices u...
In the 1990’s and early 2000’s the tax landscape in the United States was overrun by an epidemic of ...
This is Chapter 1 of Confidence Games (MIT, 2014). Confidence Games provides an account of the wave ...
Tax shelters, once thought to be extinct due to the at-risk and passive activity loss rules, continu...
This Comment will examine the history of nonrecourse financing and tax shelters from the fabled Cran...
During 1976, Congress placed some severe restrictions on tax shelter investments. In addition, even ...
Tax shelters have evoked an abundance of journalistic speculation, expertcommentary and legislative ...
After briefly reviewing the so-called abusive aspects of tax shelters which led Congress to enact th...
Tax shelters have proliferates in the United States not only because of financial innovation, the gl...
The Tax Reform Act of 1976 made sweeping changes in the area of tax shelters. Real estate tax shelte...
There continues to be heated discussion about tax reform in the area of real estate tax shelters. In...
The main question this article will discuss is whether the inability of a client to rely on a client...
This Article considers the role of tax lawyers in the corporate tax shelter controversy. In the mid-...