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Thursday, Could 18, 2023
Foster: Reckoning With Tax Danger
William E. Foster (Arkansas; Google Scholar), Reckoning with Tax Danger, 42 Va. Tax Rev. 473 (2023):
Whether or not a enterprise is partaking in a serious transaction or just conducting day-to-day operations, it should tackle tax questions and take positions based mostly on out there authority and its urge for food for danger. With sufficient analysis, most tax questions are answerable at a excessive stage of consolation, however many aren’t. This text appears at how companies take care of the latter state of affairs.
It examines how companies handle tax dangers, massive and small, distant and imminent, and it opinions the evolving toolbox for these searching for to comprise the draw back potential when making judgment calls within the absence of direct authority. This text describes the standard toolkit for addressing tax danger earlier than analyzing the rising marketplace for tax insurance coverage. It considers the advantages of development within the tax insurance coverage market whereas questioning whether or not the proliferation of personal options like tax insurance coverage may exacerbate uncertainty brought on by a relative dearth of publicly out there steerage and probably undermine sure constraints on tax practitioners.
https://taxprof.typepad.com/taxprof_blog/2023/05/foster-reckoning-with-tax-risk.html
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