The column, appearing in Monday's issue of Tax Notes, the weekly magazine on federal tax policy and administration, will focus on how taxpayers and tax practitioners are coping with an ever- increasingly complex tax code. The column will also appear in Tax Notes Today, the daily online publication.
In the inaugural column, the author discusses whether it is appropriate for a tax administrator to write rules that may not be in accordance with the statute but may provide an appropriate policy result. The column also addresses the codification of the economic substance doctrine in light of Notice 2010-62. Specifically, it looks at whether, in the absence of additional published guidance, public statements by government officials about the codified doctrine can or should be relied on by taxpayers and tax practitioners.
About the AuthorMonte Jackel, who is a managing director in the Washington National Tax office of PwC US, often writes and speaks publicly about partnership taxation and on general issues of tax policy, such as on the recently codified economic substance doctrine. He currently writes a regular column in Tax Notes titled "The Partnership Tax Report", dealing with issues of import in the area of partnership taxation. He has held several important positions with the IRS chief counsel's national office in Washington, and with the Treasury Department's Office of Tax Policy. In this column, Mr. Jackel is writing on his own behalf; his views do not represent those of PwC or any other person or organization.
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