Overview

The changing economic landscape places great stress on the tax legislative process. This stress is magnified by flaws in existing statutes, and by taxpayer attempts to exploit those flaws. There are no statutory rules governing hundreds of billions of dollars of annual transactions. Much of this void is filled in (imperfectly) by Treasury regulations.

This practicum took a close look at one or two issues raised by one proposed Treasury regulation of hundreds of billions of dollars of annual transactions. They researched the relevant literature, interviewed stakeholders, and, in their individual names, provided public comments and testimony to the Treasury Department. Ultimately, they wrote a public comment, which will be published in the leading tax journal, Tax Notes.