AALS Update: Thursday morning I will be presenting "Two and Twenty" to the AALS Section on Agency, Partnerships & LLCs. The article provides a menu of reform options for taxing partnership profits.
Given the mostly non-tax audience, I will be focusing on (1) how the flexibility of the partnership form (generally a good thing for business) creates opportunities for tax planning (and headaches for tax authorities) and (2) how the partnership rules, designed with small business in mind, are being used by large investment funds. My panel includes Larry Ribstein, Robert Sitkoff, and Brett Freudenberg. Deborah DeMott will comment on my piece.
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