University of Chicago Law School--67th Annual Federal Tax Conference Papers (Special TAXES Magazine Issue)

The University of Chicago Law School held its 67th Annual Federal Tax Conference at the business schools Gleacher Center on November 7 and 8, 2014. The papers presented at this prestigious event are published annually in this special, expanded issue of TAXES The Tax Magazine. The following articles, all of which are inlcuded in this Special Issue, are based on papers presented at the November, 2014 conference: The Code Sec. 367(d) Paradox: Peering into the Abyss from a Safe Distance By Eric B. Sensenbrenner (Skadden, Arps, Slate, Meagher & Flom LLP) Has Code Sec. 304 Run Its Course? By Pardis Zomorodi (Latham & Watkins) Busting Tax-Free Treatment By Suresh T. Advani (Sidley & Austin LLP) Intentionally Disqualified Tax-Free Corporate Transactions By Jeffrey T. Sheffield (Kirkland & Ellis) Is Debt vs. Equity Different in a Partnership By Steven R. Schneider (Goulston & Storrs P.C.) Is an Explicit Tax Election the Solution to the Debt / Equity Classification Problem for Partnerships? By Heather M. Field (University of California, Hastings College of the Law) In Search of a Normative Theory of Partnership Taxation for International Tax (or How We Learned to Stop Worrying and Love Subchapter K) By Christopher Trump and Mark Graham (Deloitte) The Omnipresence of Subchapter K in the International Arena? By Philip F. Postlewaite (Northwestern University School of Law) Audits of Partnership, TEFRA and Partnership Noncompliance: Where We Are and Where We Are Going By Noel P. Brock (West Virginia University, School of Business and Economics) Other content included in the U. of C. Law School Conference Issue includes: -- Tax Trends: Prospects for Tax Reform in 2015 (Mark Luscombe Principle Analyst Wolters Kluwer) -- International Tax Watch: Form of Transaction Allows Taxpayer to Avoid OFL and SLL Recapture (John D. McDonald and Stewart R. Lipeles (Baker & McKenzie LLP) -- Tax Practice: Receivership as a Tax Collection Tool (William D. Elliott) -- Employee Benefits Corner: Legal Changes for Qualified Plans (Elizabeth Thomas Dold and David N. Levine, Groom Law Group, Chartered) -- Salt Block: Domicile: The Foundation of State Individual Taxation (Blaise M. Sonnier (University of Colorado) -- The Estate Planner: Planners Toolbox: GRATS (Lewis J. Saret)