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Full-Text Articles in Law
Advocating A Carryover Tax Basis Regime, Richard Schmalbeck, Jay A. Soled, Kathleen Delaney Thomas
Advocating A Carryover Tax Basis Regime, Richard Schmalbeck, Jay A. Soled, Kathleen Delaney Thomas
Notre Dame Law Review
For close to a century, an important (but unfortunate) feature of the Internal Revenue Code has been a rule that the tax basis of any inherited asset is made equal to its fair market value at the time of the decedent’s death. Notwithstanding the substantial revenue losses associated with this rule, Congress has retained it for reasons of administrative convenience.
But from three different vantage points, pressure has been mounting to change what is commonly referred to as the “step-up in basis rule.” First, politicians and commentators have historically tied the step-up in basis rule to the estate tax on …
Citizens Abroad And Social Cohesion At Home: Refocusing A Cross-Border Tax Policy Debate, Michael Kirsch
Citizens Abroad And Social Cohesion At Home: Refocusing A Cross-Border Tax Policy Debate, Michael Kirsch
Journal Articles
Modern developments raise significant questions about the future importance (or non-importance) of formal citizenship status. For example, while many have interpreted the European Union project, with its emphasis on the free movement of individuals, as portending the decreasing relevance of nationality, recent developments, such as the “Brexit” vote, suggest that national identity remains an important factor for many individuals. While much of the public debate over citizenship focuses on areas, such as immigration, that are more obviously tied to formal citizenship status, this debate also impacts cross-border tax policy.
Over the past decade, several scholars have addressed the use of …