This article discusses the potential benefits of utilizing critical tax theory to enhance traditional tax policy analysis. The article demonstrates that because traditional tax policy presumes that taxpayer income level is the only salient factor in tax equity analysis, it fails to consider any...

This article examines the effect of debt-financed distributions on the 10-year basis step-up of investments in qualified opportunity fund partnerships. The article explores possible outcomes under relevant Treasury and IRS guidance, discusses the related policy implications, and makes...