For the Press

Tax Analysts Announces New Regular Column Analyzing Ambiguous Corporate Tax Policies

June 10, 2013

FALLS CHURCH, Va. – Tax Analysts, the nonprofit provider of federal, state, and international tax news and analysis, today announced the launch of a new column, Willis Weighs In, written by frequent contributor Benjamin M. Willis. The regular column will appear in Tax Analysts’ Tax Notes and Tax Notes Today publications and will provide analysis on ambiguous corporate tax policies.


Willis’s first column, "A Principal Purpose: There Can Be Only One," explores the confusion created by the different interpretations of the principal purpose of tax avoidance standard. Willis explains why the IRS should adhere to the Supreme Court’s conclusion that the term ‘‘principal’’ is synonymous with ‘‘of first importance.’’

“The principal purpose of tax avoidance standard (the standard) was seemingly well understood by all, at least until recently,” Willis writes. “The historic interpretation of the standard is consistent with the government’s long-standing announced policy of eliminating confusing tax rules. Nonetheless, in recent regulations the IRS appears to present paradoxical interpretations of the standard, contrary to the government’s stated policies on drafting regulations and common-sense meanings.”

Willis is a member of PricewaterhouseCoopers's National Tax Services Mergers & Acquisitions group. He is a full-time client adviser assisting U.S. multinationals with corporate tax planning, organizational restructurings, acquisitions and divestitures, and IRS examinations. Willis earned his LLM in taxation from Boston University, his JD from New England School of Law, and his BA from the University of Rhode Island.

Tax Notes and Tax Notes Today are Tax Analysts publications dedicated to federal tax laws, regulations, and policy developments.

A full copy of Willis’s new column is available here.

For more information, please contact Shaima Cardillo at 703-531-4852 or