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"The Taxation of Financial Arrangements (TOFA) Proposals: A Modest and Defensible Agenda for Reform"    

Cases and Articles Cited

Case Name	Citation(s)	Court	Jurisdiction	Date	Full Text		Citation Index †
"Taxation Without Realization: A ‘ Revolutionary ’ Approach to Ownership"	47 Tax Law Review 725	Tax Law Review	United States		HeinOnline / Westlaw		4
"Interpreting the Income Tax Act - Part 2: Toward a Pragmatic Approach"	(1999) 47 Canadian Tax Journal 741	Canadian Tax Journal	Canada	circa 1999			3
"Financial Contract Innovation and Income Tax Policy"	(1993) 107 Harvard Law Review 460	Harvard Law Review	United States	circa 1993	HeinOnline / LexisNexis		3
"Formalism in Tax Law"	66 University of Chicago Law Review 860	University of Chicago Law Review	United States		HeinOnline / LexisNexis		3
"Line Drawing, Doctrine, and Efficiency in the Tax Law"	(1999) 84 Cornell Law Review 1627	Cornell Law Review	United States	circa 1999	HeinOnline / LexisNexis		2
(2000) 48 Canadian Tax Journal 1	(2000) 48 Canadian Tax Journal 1	Canadian Tax Journal	Canada	circa 2000			1
"Further Reflections on Derivative Taxation"	(1999) 47 Canadian Tax Journal 534	Canadian Tax Journal	Canada	circa 1999			1
"The Taxation of Complex Financial Instruments"	(1998) 43 Tax Law Review 731	Tax Law Review	United States	circa 1998	HeinOnline / Westlaw		1
"Saving the Income Tax: An Agenda for Research"	(1998) 24 Ohio Northern University Law Review 493	Ohio Northern University Law Review	United States	circa 1998	HeinOnline / LexisNexis		1
"The Influence of Tax Law on Securities Innovation in the United States: 1981-1997"	(1997) 52 Tax Law Review 119	Tax Law Review	United States	circa 1997	HeinOnline / Westlaw		1
"Another Uneasy Compromise: The Tax Treatment of Hedging in a Realization Income Tax"	(1996) 3 Florida Tax Review 1	Florida Tax Review	United States	circa 1996	HeinOnline / Westlaw		1
"The Accrual of Interest on Derivatives: Where Do We Go From Here?"	(1996) 74 Taxes The Tax Magazine 1011	Taxes: The Tax Magazine	United States	circa 1996	HeinOnline		1
"Flying on Instruments: Synthetic Investment and the Avoidance of Withholding Tax"	(1996) 13 Tax Notes International 1625	Tax Notes International	United States	circa 1996			1
"Apocalypse Not?"	(1995) 50 Tax Law Review 833	Tax Law Review	United States	circa 1995	HeinOnline / Westlaw		1
"Tax Responses to Financial Contract Innovation"	(1995) 50 Tax Law Review 491	Tax Law Review	United States	circa 1995	HeinOnline / Westlaw		1
"Commentary"	(1995) 50 Tax Law Review 725	Tax Law Review	United States	circa 1995	HeinOnline / Westlaw		1
"Looking Forward into the Past: Financial Innovation and the Basic Limits of Income Taxation"	(1995) 43 Canadian Tax Journal 1144	Canadian Tax Journal	Canada	circa 1995			1
"Different Rules for Different Players and Products: The Patchwork Taxation of Derivatives"	(1994) 72 Taxes The Tax Magazine 1031	Taxes: The Tax Magazine	United States	circa 1994	HeinOnline		1
"Taxing New Financial Products: A Conceptual Framework"	(1994) 46 Stanford Law Review 569	Stanford Law Review	United States	circa 1994	HeinOnline / LexisNexis		1
"A General Approach to the Taxation of Financial Instruments"	(1992) 71 Texas Law Review 243	Texas Law Review	United States	circa 1992	HeinOnline / LexisNexis		1
"Bifurcation of Financial Instruments"	(1991) 69 Taxes The Tax Magazine 821	Taxes: The Tax Magazine	United States	circa 1991	HeinOnline		1
"New Rules on Bifurcating Contingent Debt – A Mistake?"	(1991) 51 Tax Notes 235	Tax Notes	United States	circa 1991			1
"Carving Up Assets and Liabilities – Integration or Bifurcation of Financial Products"	(1990) 68 Taxes The Tax Magazine 1003	Taxes: The Tax Magazine	United States	circa 1990	HeinOnline		1
"Beyond Good and Evil Debt (And Debt Hedges): A Cost of Capital Allowance System"	(1989) 67 Taxes The Tax Magazine 943	Taxes: The Tax Magazine	United States	circa 1989	HeinOnline		1
"Contingent Payments and the Time-Value of Money"	(1987) 40 Tax Lawyer 237	Tax Lawyer	United States	circa 1987	HeinOnline		1
"The Tax Treatment of Hedged Positions: What Hath Technical Analysis Wrought?"	50 Tax Law Review 803	Tax Law Review	United States		HeinOnline / Westlaw		1