The Federal Lawyer

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Rulings Shed Some Light on the Application of Partnership Merger and Division Rules, but Not a Roadmap
Transactions involving partnerships can be tricky to characterize for U.S. federal income tax purposes, to say the least. Too often, the results can be unexpected and counterintuitive, and the complexity can dramatically increase in cases identical letter rulings that involved a multistep transaction and the treatment for U.S. federal income tax purposes as a partnership division followed immediately after by a partnership merger can shed light on the issues.

Features

Film Financing and Tax Policy
Is there something amiss when the film adaptation of a national book award winner about the American Civil War is filmed in Romania? Perhaps it is part of the magic of the movies that a post-Soviet era Eastern European country can be made to look like Appalachia, but the magic of the movies costs money.
It Takes Two (Transactions) to Fix Things Right: A Review of Giant Eagle and a Potential Way Forward for Taxpayers
The thought of earning rewards at a store at which you already shop can be considered a win-win for both the consumer and the offering entity. Consumer loyalty programs drive initial sales at a store, repeat sales, and overall loyalty to that brand. Many of these programs, especially those in the retail space, provide points or discount coupons that can be redeemed with a future purchase, thereby driving future sales.
The New ALI Restatement and the Doctrine of Non-Self-Executing Treaties
At its annual meeting in May 2017, the American Law Institute (ALI) approved a new Restatement on Treaties as part of a broader project on Foreign Relations Law. The reporters deserve much praise for their excellent work on treaties. However, this article criticizes their approach to the doctrine of non-self-executing (NSE) treaties and the related topic of treaty supremacy.
We Didn't Start the Fire: The Unknown History of Flag Desecration in America
In the wake of the presidential election of 2016, college students at several campuses around the country posted online videos of themselves burning American flags. In response, President-elect Donald J. Trump tweeted on Nov. 29, "Nobody should be allowed to burn the American flag - if they do, there must be consequences - perhaps loss of citizenship or year in jail!"