In a follow-up letter to the editor recently published by Tax Notes International, Michael Karlin continues his debate about Moore v. United States, responding to Professor Reuven S. Avi-Yonah and Professor Mindy Herzfeld’s criticisms of the Moores’ tax planning when they invested in an Indian company. Michael argues strongly against the idea that the Moores should have considered alternate strategies when making their investment so as to avoid tax consequences, stressing that no individual taxpayer could have predicted changes that would come years later.
Read Michael’s full comments in the letter below.