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  • David Schizer

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Sticks and snakes: derivatives and curtailing aggressive tax planning

Complex “derivative” financial instruments are often used in aggressive tax planning. In response, the government has implemented mark-to-market type reforms, but only partially. Considered in...

Understanding Venture Capital Structure: A Tax Explanation for Convertible Preferred Stock

The capital structures of venture capital-backed U.S. companies share a remarkable commonality: overwhelmingly, venture capitalists make their investments through convertible preferred stock.[1 ] Not surprisingly,...

Enlisting the Tax Bar

Abstract Tax shelters and aggressive planning derive in part from a structural imbalance in our tax system that has not been adequately explored: In important...
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