June 12th, 2026

In the May/June Issue of the Journal of Corporate Taxation, I had the pleasure, as Editor-in-Chief and Columnist on Cross-Border Taxation, to interview Terrence ("Terry") Cuff. Terry is an outstanding tax lawyer who has over 45 years of experience in partnership taxation, real estate taxation, and the taxation of real estate investment trusts (REITs) at Loeb & Loeb LLP. He is presently Of Counsel to the firm in its LA office. He has advised large corporations, energy companies, financial institutions, and real estate investors on complex tax and transactional issues. In addition to his academic achievements at law school (USC, Order of the Coif), NYU LL.M. in Taxation, he also served in the U.S. Marine Corps. He serves on the Advisory Board of Corporate Taxation and is a member of the California bar.

Terry is a long-time friend and colleague, and we have worked together on various projects and seminars for many years. He is quite knowledgeable in many areas of the tax code, particular partnership taxation and partnership agreements and law, as well as sales and exchanges, REITs and other areas. In addition to his countless published articles on important federal tax issues, he is the author of an outstanding legal treatise, "Drafting Partnership and LLC Allocation and Distribution Provisions" (Thomson Reuters) 2025 edition available in eBook (Thomas Reuters ProView") and print format and can be access on WESTLAW. A host of Terry's publications can be accessed through Thomson Reuters Checkpoint or Lexis Nexis (NYU Annual Institute of Federal Taxation).

I thought the readers of the Journal of Corporate Taxation, which can be received through the internet (by subscription to RIA Checkpoint and/or WESTLAW) and published in print form, would enjoy hearing Terry's present views on the hyper-complex world of partnership taxation and his suggestions for fixing it. Thomson Reuters was kind to supply us with the Interview in the May/June 2026 issue recently published version to be sent out with this blog post. I also had the pleasure of previously interviewing Terry on federal tax matters, including partnership taxation, which also appeared in Corporate Taxation (March/April 2022).

I hope you will enjoy reading the Interview.

JCT_May_June_2026

As a "footnote", Senator Wyden (D-Ore) who serves as Minority Chief on the Senate Finance Committee of Congress, has been highly critical of tax planning strategies and corporate tax shelters. During the Biden Administration and then Majority Chief of the SFC, Senator Wyden proffered reforms to partnership taxation, and several are quite controversial. Senator Wyden has not forgotten about this list and should the Congress tilt back to the Democratic Party these "reforms" may well be given first consideration for closing loopholes of big corporations and wealthy individuals. A few are mentioned in the Interview with Mr. Cuff. These items are discussed in an article I published several years ago. See August "The “No-Look, Just Pass It” Legislation to Prevent Abuse of Partnerships by Wealthy Investors and Mega-Corporations to Avoid Paying Tax" Corporate Taxation" (WG&L), Sep/Oct 2021. Don't forget the Biden Administration's increase in the corporate tax rate to 28%. That's not hard to forget.

If you have any questions or observations for Mr. Cuff, please forward them to me and I make sure he sees them.

Jerry August