On January 24, 2013, Congressman Dave Camp (R-MI), the Chairman of the House Ways and Means Committee, released the discussion draft of a bill that would tax derivatives under a mark-to-market system of taxation. This truly Copernican proposal would replace our entire federal system of taxing...

On September 17, 2015, the IRS and the Treasury Department issued final, temporary, and proposed regulations under section 871(m) of the Internal Revenue Code that provide the rules for withholding on “dividend equivalent payments” on derivatives that reference U.S. equity securities. In...

Congress could very easily achieve return-free filing – without IRS involvement or any substantive changes to the tax code – by simply requiring all tax information providers (such as employers, banks, stock brokerage firms, and charities) to make the tax information they hold (e.g.., IRS...

The 2017 tax legislation brought sweeping changes to the rules for taxing individuals and business, the deductibility of state and local taxes, and the international tax regime. The complex legislation was drafted and passed through a rushed and secretive process intended to limit public comment...

On October 19, 2018, the Internal Revenue Service and the U.S. Department of the Treasury issued proposed regulations under section 1400Z-2 of the Internal Revenue Code regarding the qualified opportunity zone program.This paper summarizes some of the most important aspects of the proposed...