All of Stephen's Publications

Taxpayers are subject to a duty of consistency in applying tax treaties. This paper seeks to remedy the gap in scholarship on the topic by providing a comprehensive study of the issue.

This article explores the problems inherent in classifying debt as bearer or registered under a variety of arrangements for issuance and trading. The article also addresses related issues under the rules restricting the issuance and holding of bearer debt.

This article explores the problems inherent in classifying debt as bearer or registered under a variety of arrangements for issuance and trading. The article also addresses related issues under the rules restricting the issuance and holding of bearer debt.

The first version of this article was published in The Tax Lawyer under the title “Partnership Revaluations.”

I had the feeling, and still do, that the growth of derivatives poses a serious challenge to the tax law’s attempt to tax different classes of income differently

This was one of the first occasions for the use of the “Pac-Man” defense, where the target launches a counterattack by buying shares of its purported acquirer.

Even when tax rates are stable, there is an economic benefit to deferring payment of tax, which is worth as much as a complete exemption of the return on the tax deferred.

This paper was first written in 1979 while I was still in law school, for a seminar on Corporate Tax Policy taught by Prof. Bernard Wolfman.