Tax Matters

Vol. 5, No. 2

Each edition of Tax Matters consists of free-flowing responses by three tax practitioners to a question regarding a current issue in tax law and policy. Tax Matters commentaries provide insightful perspectives on a broad range of topics, making important contributions to the dialogue within the tax bar about cutting-edge issues. Although the commentaries are certainly of interest to the academic community, they are primarily directed toward tax professionals and their clients.


Section 871(m) and Delta: When Should a Dividend Be Treated like a Dividend?

Mike Farber


Taxation Without Authorization: The Proposed “Dividend Equivalent” Withholding Regulations Under Section 871(m)

Linda Z. Swartz, Shlomo Boehm & Jason Schwartz


The Most Recent Proposed Regulations Under Section 871(m): The Perfect Is the Enemy of the Good

Andrew Walker