Head of BSF Tax Practice Mike Kosnitzky Comments on Supreme Court Tax Disputes
International Tax Review, 05.03.2012
The International Tax Review called upon BSF partner Mike Kosnitzky for comment on their article, "How to Win a US Tax Dispute." The article can be accessed by clicking here (subscription required). An excerpt is below:
Michael Kosnitzky, a tax partner at Boies, Schiller & Flexner, said tax laws are often written too broadly, especially when it comes to tax shelters or alleged tax shelters, or they give the treasury broad interpretive authority which creates further ambiguities.
“It isn’t always good for the treasury to tell the taxpayer exactly where the line is in any particular situation but rather to keep the line a bit blurry,” said Kosnitzky.
“Legislative intent is often very difficult to discern and oftentimes cannot always be relied upon for guidance especially when applied to specific fact patterns not contemplated by the draftsmen of the legislation,” he added.
Related Lawyer: Michael Kosnitzky
Related Practice: Tax