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103 Minn. L. Rev. 1439 (2018-2019)
The Games They Will Play: Tax Games, Roadblocks, and Glitches under the 2017 Tax Legislation

handle is hein.journals/mnlr103 and id is 1475 raw text is: 











Article


The Games They Will Play: Tax Games,
Roadblocks, and Glitches Under the 2017
Tax   Legislation


David   Kamin, David Gamage, Ari Glogower,
Rebecca Kysar, Darien Shanske, Reuven Avi-
Yonah,   Lily  Batchelder, J. Clifton Fleming,
Daniel   Hemel, Mitchell Kane, David Miller,
Daniel   Shaviro,   &  Manoj   Viswanathant



Introduction         ................................ ..... 1441
I.  Using Corporations  as Tax Shelters     ............... 1445
    A. The  Two-Step  Game  for Sheltering Income
       Through  a Corporation    .................  ..... 1446


    t  The complete list of authors with affiliations is as follows: David Kamin,
Professor of Law, NYU School of Law; David Gamage, Professor of Law, Indiana
University Maurer School of Law; Ari Glogower, Assistant Professor of Law,
The Ohio State University Moritz College of Law; Rebecca Kysar, Professor of
Law, Fordham University School of Law; Darien Shanske, Professor of Law, UC
Davis School of Law; Reuven Avi-Yonah, Irwin I. Cohn Professor of Law, Uni-
versity of Michigan Law School; Lily Batchelder, Frederick I. and Grace Stokes
Professor of Law, NYU School of Law; J. Clifton Fleming, Ernest L. Wilkinson
Chair and Professor of Law, J. Reuben Clark Law School, Brigham Young Uni-
versity; Daniel Hemel, Assistant Professor of Law, University of Chicago Law
School; Mitchell Kane, Gerald L. Wallace Professor of Taxation, NYU School of
Law; David Miller, Partner, Proskauer Rose, LLP; Daniel Shaviro, Wayne Perry
Professor of Taxation, NYU School of Law; & Manoj Viswanathan, Associate
Professor of Law, UC Hastings College of the Law.
    David Kamin is the primary organizer for this project and is thus listed as
the first author. The other primary drafters are listed next in alphabetical or-
der-David Gamage, Ari Glogower, Rebecca Kysar, and Darien Shanske-fol-
lowed by the remaining authors, also listed in alphabetical order.
    Beyond the listed authors, this article reflects insights from many other tax
scholars, practitioners, and analysts, as acknowledged in the footnotes to the
text. All errors are our own. Copyright 0 2019 by David Kamin, David Gamage,
Ari Glogower, Rebecca Kysar, Darien Shanske, Reuven Avi-Yonah, Lily
Batchelder, J. Clifton Fleming, Daniel Hemel, Mitchell Kane, David Miller,
Daniel Shaviro, and Manoj Viswanathan.


1439

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