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Some coauthors dissent from withdrawal of report, for which key findings have been independently confirmed

Some coauthors dissent from withdrawal of report, for which key findings have been independently confirmed

The University of Chicago Law School held its 64th Annual Federal Tax Conference at the business school’s Gleacher Center on a memorable date: 11/11/11. Published exclusively each year in the special March Issue of Taxes—The Tax Magazine are the papers presented at this prestigious conference.

• The Past and Future of the Foreign Tax Credit (By Philip R. West and Amanda P. Varma)
• PFICs (By Kimberly S. Blanchard) discussing the policy and purpose of the PFIC rules and suggesting ways in which the PFIC rules could be made more workable by IRS guidance.
• Mayo Deference Examined Under the Six-Year Statute of Limitations Cases—A Proposal for a Constitutionally Sound Allocation of Lawmaking Authority (By Irving Salem) discussing the proper role of judicial deference to the agency.
• Updating the Tax-Free Reorganization Rules—Attributes, Overlaps and More (By Michael L. Schler, Eric Solomon, Karen Gilbreath Sowell, Jonathan J. Katz and Gary Scanlon) analyzing tax-free reorganization rules.
• To Err is Human; to Rescind, Divine (By Philip B. Wright) examining the role of rescission and other remedies to retroactively alter the tax consequences of a prior transaction.
• The Mysterious Case of Disappearing Debt in Partnership Transactions (By Phillip Gall and Franny Wang) analyzing the five primary cases of disappearing debt in partnership transactions.
• Employee Benefits Corner (by By Elizabeth Thomas Dold and David N. Levine) covering all types of employee benefits, including qualified plans, IRAs, governmental plans, nonqualified deferred compensation plans, and health and welfare plans.
• The Estate Planner (By Lewis Saret) examining the tax and legal aspects of trusts and estates and significant current developments
• International Tax Watch (By Stewart R. Lipeles, John D. McDonald) looking at the world of tax beyond the U.S.
• Tax Practice (By William D. Elliott) focusing on tax practice and procedure issues.
• Tax Trends (By Mark Luscombe) keeping you up-to-date on the latest trends in the tax world.

Special Feature:

• Unwinding or Rescinding A Transaction: Good Tax Planning or Tax Fraud (by Sheldon I. Banoff). In the seminal 1984 article, Shelly examines when unwinding, rescission or substantial modification will be respected for federal tax purposes.

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