Welcome to TaxBlawg, a blog resource from Chamberlain Hrdlicka for news and analysis of current legal issues facing tax practitioners. Although blawg.com identifies nearly 1,400 active “blawgs,” including 20+ blawgs related to taxation and estate planning, the needs of tax professionals have received surprisingly little attention.
Tax practitioners have previously lacked a dedicated resource to call their own. For those intrepid souls, we offer TaxBlawg, a forum of tax talk for tax pros.
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Earlier this year, my former colleague Jonathan Prokup and I published an article in the Journal of Taxation and Regulation of Financial Institutions. In the article, we considered the federal tax consequences of Treasury's capital purchase program – the centerpiece of TARP. Under the program, Treasury invested several hundred billion dollars into hundreds of our country's banks to alleviate their perceived liquidity problems, which many believed to be the cause of the unfolding financial crisis.
Our article concluded that, even though most TARP instruments were nominally ...