Deputizing the Gunslingers: Co-Opting the Tax Bar into Dissuading Corporate Tax Shelters
64 Pages Posted: 29 Jun 2001
Date Written: 2001
"Deputizing the Gunslingers" discusses the role of lawyers in fostering abusive corporate tax shelters and focuses on the non-statutory constraints that are available to curtail such activities. The article takes the position that even if Congress ultimately lacks the political will to affirmatively legislate against such tax shelters, the tax bar and individual tax attorneys should recognize their duty in maintaining a fair tax system and take actions aimed at dissuading clients from engaging in abusive transactions. The paper discusses relevant ethical rules, malpractice liability issues, reputation concerns and other approaches that can help turn the hired guns of the corporate elite into deputies of the tax system.
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