



CONTENTS
ARTICLES
Whistleblowers and Tax Enforcement: Using Inside Information to Close the “Tax Gap”
Edward A. Morse
--Page 1
Surviving a Heart Attack: Expatriation and the Tax Policy Implications of the New Exit Tax
Steven J. Arsenault
--Page 37
Opinions on the Ethics of Tax Evasion: A
Comparative Study of the USA and
Six Latin American Countries
Robert W. McGee
Wendy Gelman
--Page 69
Honorary Board Membership, Real Tax Liability: Limits to Tax-Exempt Organization Honorary Board Member Immunity Under Internal Revenue Code § 6672
Kenneth H. Ryesky
--Page 93
Built-In Gain Discounts for Transfer Tax Valuation: A Resolution for the BIG Debate
Scott Andrew Bowman
--Page 117
The Tax Debts of Small Business Owners in Bankruptcy
Rafael Efrat
--Page 175