Uncle Sam is getting seriousabout tax shelters, and not justthe kind yourgrandmother used to bake.

Grandma, for certain,thought a FLIP (foreign leveraged investment program)was what she didwith her pancakes andthat a SOS (short-optionstrategy) was the distresssignal she learnedin Morse Code. But corporatecounsel, particularly in thecurrent climate of corporate scandal andmanagement insecurity, cannot afford tobe so naive.

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