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Full-Text Articles in Tax Law
Untangling The Strings: Transfer Taxation Of Retained Interests And Powers, Matthew A. Reiber
Untangling The Strings: Transfer Taxation Of Retained Interests And Powers, Matthew A. Reiber
Akron Law Review
This Article takes a more sanguine approach: it acknowledges the utility of certain portions of these provisions to a functioning transfer tax system, but ultimately concludes that the current statutory scheme is overbroad in reach, clumsy in application, and therefore should be replaced with a single, stand-alone provision. Such a provision would require inclusion of property irrevocably transferred during life in which (a) the transferor retains an economic interest in the property, such as the right to use the property or to receive the income generated by the property, (b) the transferor pays gift tax at the time of transfer …
Individual, Couple Or Family? The Unit Of Taxation For Transfer Tax Purposes: A Shifting Focus, Anne-Marie Rhodes
Individual, Couple Or Family? The Unit Of Taxation For Transfer Tax Purposes: A Shifting Focus, Anne-Marie Rhodes
Akron Law Review
This paper examines the shifting focus of the transfer tax system from the perspectives of the articulated primary purpose for the taxes and the appropriate unit of taxation given that purpose. The historical progression shows that as a sense of purpose became less clear, the unit of taxation similarly became less focused.
Taxation Expatrition: Will The Fast Act Stop Wealthy Americans From Leaving The United States?, Beckett G. Cantley
Taxation Expatrition: Will The Fast Act Stop Wealthy Americans From Leaving The United States?, Beckett G. Cantley
Akron Law Review
In the wake of September 11, 2001, several influential lawmakers have sought to pass tax legislation that would reduce the tax benefits that may result from an American citizen expatriating to a foreign nation. According to these congressional critics, certain wealthy American citizens are willing to relinquish their United States citizenship to save taxes (“tax expatriates”). The last major attempt to prevent tax expatriation was undertaken in 1995 when Internal Revenue Code (“I.R.C.”) § 877 was enacted. Several congressional critics have charged that I.R.C. § 877 is being easily circumvented by tax expatriates and their advisors. To stem the tide …