Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

Tax Law

Selected Works

2014

Professional responsibility

Articles 1 - 3 of 3

Full-Text Articles in Law

Cobra Strikes Back: Anatomy Of A Tax Shelter, Karen C. Burke, Grayson M.P. Mccouch Nov 2014

Cobra Strikes Back: Anatomy Of A Tax Shelter, Karen C. Burke, Grayson M.P. Mccouch

Karen Burke

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. …


Cobra Strikes Back: Anatomy Of A Tax Shelter, Karen C. Burke, Grayson M.P. Mccouch Nov 2014

Cobra Strikes Back: Anatomy Of A Tax Shelter, Karen C. Burke, Grayson M.P. Mccouch

Grayson McCouch

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. …


Problems In Tax Ethics, Donald Tobin, Richard Lavoie, Richard Trogolo Jun 2014

Problems In Tax Ethics, Donald Tobin, Richard Lavoie, Richard Trogolo

Donald B. Tobin

The ethical issues and problems facing tax lawyers and tax professionals have become increasingly complex, and the general rules of professional responsibility do not always provide clear answers to the problems tax professionals face. This book examines the Model Rules of Professional Responsibility, statutory and regulatory rules governing tax practice and uses problems to explore the application of these rules in the tax context. As financial scandals continue and tax transactions become increasingly complex, people studying in this area of law need a text designed to deal with specific problems that arise often in the tax field.