Monday, September 11, 2023

Brennan & Schizer: Transaction-Specific Tax Reform In Three Steps: The Case Of Constructive Ownership

Thomas J. Brennan (Harvard) & David M. Schizer (Columbia), Transaction-Specific Tax Reform in Three Steps: The Case of Constructive Ownership:
Similar investments are often taxed differently, rendering our system less efficient and fair. In principle, fundamental

Sarkar opens with how the IRS gets entangled with ICE’s immigration raid. IRS’s Criminal Investigation (CI) division often investigates employers who fail to meet their tax obligations. IRS often seeks a search warrant of the employment site, and in doing so, it often seeks to cooperate with other law enforcement agencies for help. ICE is