These slides were prepared for lectures I gave at law schools in Shanghai and in Israel the week of November 13, while the Tax Cuts & Jobs Act of 2017 (H.R.1) was under active consideration in the U.S. House of Representatives and the Senate version of the Tax Cuts and Jobs Act was being...

The increasing use of derivatives to manage financial risks raises significant challenges for legislators and tax administrators in forging a coherent U.S. tax regime. Through the creative use of derivatives, taxpayers can transform a highly taxed return into an economically equivalent but lower...