Michael Schler (Cravath, Swaine & Moore, New York) has published Effects of Anti-Shelter Rules on Non-Shelter Tax Practice, 109 Tax Notes 915 (Nov. 14, 2005), also available on the Tax Analysts web site as Doc 2005-22068, 2005 TNT 219-41. Here is the abstract:
This article discusses the effects that certain anti-tax-shelter rules have (or would have) on a nonshelter tax practice. The author believes that antiabuse rules would not have a serious adverse effect on tax practice. However, recent requirements regarding reportable transactions and (especially) under Circular 230 have had a very burdensome effect on tax practice that appears to exceed their benefits in attacking tax shelters.




