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Full-Text Articles in Law
Why Pension Funding Matters, Eric D. Chason
Toward A Practical Estate-Tax Exclusion For Family-Run Businesses: Analysis Of Section 2033a And Proposal For Reform, Eric D. Chason, Robert T. Danforth
Toward A Practical Estate-Tax Exclusion For Family-Run Businesses: Analysis Of Section 2033a And Proposal For Reform, Eric D. Chason, Robert T. Danforth
Eric D. Chason
In a previous work appearing in this Journal, the authors proposed an approach to estate and gift taxation that encourages productive behavior by the recipients of wealth. In this Article, the authors analyze, in the context of their earlier work, the new estate-tax exclusion for closely held businesses (section 2033A) created by the Taxpayer Relief Act of 1997. The authors describe the features of a practical family-run business exclusion and conclude that section 2033A, in its present form, fails as a practical exclusion. The authors catalogue those elements of section 2033A that should be retained and propose reforms of those …
Taxing Losers, Eric D. Chason
Taxing Losers, Eric D. Chason
Eric D. Chason
The U.S. tax system, like most in the world, benefits capital gains in two ways. Investors can defer paying tax until they "realize" any gain (typically by sale) rather than when the gain simply occurs via rising prices. Additionally, individual investors pay a lower, preferred rate on their long-term capital gains as compared to their other ordinary income (such as compensation or business profits).
However, investors face a burden with respect to their capital losses. Rather than allowing for unlimited capital loss deductions, the Code largely forces investors to match their capital losses against their capital gains. Limits on capital …
The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason
The Post-Tarp Movement To Regulate Banker Pay, Eric D. Chason
Eric D. Chason
No abstract provided.
Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason
Quantifying The Tax Advantage Of Deferred Compensation, Eric D. Chason
Eric D. Chason
No abstract provided.
Naked And Covered In Monte Carlo: A Reappraisal Of Option Taxation, Eric D. Chason
Naked And Covered In Monte Carlo: A Reappraisal Of Option Taxation, Eric D. Chason
Eric D. Chason
The market for equity options and related derivatives is staggering, covering trillions of dollars worth of assets. As a result, the taxation of these instruments is inherently important. Moreover, the importance is made even more acute by the use of options in creating more complex transactions and in avoiding taxes. Consider an equity call option, which entitles, but does not obligate, its holder to buy stock at a set price at a set time in the future. Option theory gives us a way to break the option down into more fundamental units. For example, an equity call option over 10,000 …