Posts by Manoj Viswanathan

Heather Field on Tax Lawyers as Tax Insurance

Published on: Author: Manoj Viswanathan

A “tax opinion” is a formal, written statement provided by a lawyer to a client about the tax consequences of a specific transaction. In addition to describing the expected tax treatment, the opinion also specifies the lawyer’s confidence in this determination—a “will” opinion indicates near certainty; a “more likely than not” opinion is much more… Continue reading

Heather Field on “Tax Loopholes”

Published on: Author: Manoj Viswanathan

Politicians, pundits, and countless others indiscriminately describe disfavored provisions as “tax loopholes.” Yet as my colleague and fellow tax scholar Professor Heather Field demonstrates in her recently published article, A Taxonomy for Tax Loopholes, the term lacks definitional clarity. The phrase has been used, variously, to reference statutory ambiguities, violations of the spirit of the… Continue reading

Heather Field on Tax Practice and Ethics

Published on: Author: Manoj Viswanathan

Heather Field, my colleague and fellow tax scholar, has written two important articles at the intersection of the practice of tax law and professional ethics. There are scant resources for (1) tax practitioners seeking guidance on how to act ethically when making discretionary decisions involving aggressive tax planning and (2) tax law faculty who want… Continue reading