Building the New Berlin Tax Wall: Treasury’s Anti-Inversion Regulations
The analogy of U.S. corporate tax policy is the Berlin Wall, because it clearly illustrates the melding of bad policy and all-but-certain failure.
As the World Churns: Avoiding Tax Planning Disaster by Avoiding Anti-Churning Rules
The anti-churning rules have created a complex and burdensome trap and catch more M&A transactions than you might suspect.
When Undoing the Deal Is the Best Tax Deal
If a transaction has gone badly, sometimes a far better resolution is to consider whether it is possible to rescind or unwind the transaction.
The Tall Tax Tale of Why Country Songwriters Get Capital Gain Treatment
This tax tale is worthy of a country ballad, but I won't make you suffer through a bushel of forced metaphors while I tell it.