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Full-Text Articles in Tax Law

Front Matter Jun 2026

Front Matter

ACTEC Law Journal

No abstract provided.


Time Lapse: Deducting Claims And Expenses Under Section 2053, Grayson M.P. Mccouch Jun 2026

Time Lapse: Deducting Claims And Expenses Under Section 2053, Grayson M.P. Mccouch

ACTEC Law Journal

No abstract provided.


Fetal Personhood And Inheritance By Unborn Children, Alyssa A. Dirusso, Emily Price Jun 2026

Fetal Personhood And Inheritance By Unborn Children, Alyssa A. Dirusso, Emily Price

ACTEC Law Journal

This article will first discuss the status of the law with respect to inheritance rights of the unborn, including both posthumous children and posthumously-conceived children. This paper next describes the fetal personhood movement and its recognition of not only life but also death before birth. The article explains the current law on survivorship and inheritance rights. Then this article discusses the implications of death before birth on intestate distributions. These implications lead the authors to recommend a default rule barring unintentional nevernatal inheritance. The authors support, however, practical provisions for the unborn for those who choose to do so.


"Health" In Hems Means Complete Well-Being, Claudia E. Tordini, Richard S. Franklin Jun 2026

"Health" In Hems Means Complete Well-Being, Claudia E. Tordini, Richard S. Franklin

ACTEC Law Journal

This article focuses on the definition of “health” as used in the ascertainable standard exception of Internal Revenue Code § 2041(b)(1)(A), most frequently articulated in trusts as “health, education, maintenance and support” (HEMS). It is clear that a discretionary power to distribute for one’s own health is permitted without causing a taxable general power of appointment, but there is a dearth of authority indicating the meaning of health for this purpose. This article provides the research and foundation for understanding that health as used in HEMS is a state of complete physical, mental, and social well-being, and not merely the …


Front Matter Sep 2025

Front Matter

ACTEC Law Journal

No abstract provided.


Private Functional Wildlife Trusts, Stuart W. Babcock Sep 2025

Private Functional Wildlife Trusts, Stuart W. Babcock

ACTEC Law Journal

Public wildlife law is clear: wild animals exist and are managed for the public writ large. This is a mistake. Wild animals are beings of moral concern; their lives can be good or bad, better or worse, and they should be treated accordingly. This article explores a novel legal instrument which can account for wild animals' unique interests and circumstances: private wildlife trusts, in which wild animals are the trust beneficiaries. Wildlife trusts pose distinctive management and implementation challenges. This article aims to provide a path forward for wildlife advocates seeking new tools to protect wild animals and the habitats …


Law Firms As Trust Directors, Raymond C. O’Brien Sep 2025

Law Firms As Trust Directors, Raymond C. O’Brien

ACTEC Law Journal

The practice of permitting a third party, other than a settlor or a trustee, to give guidance to the trustee over some aspect of trust management reflects the trend of granting settlors increasing control over their transfers of wealth. In decades past, a few states enacted legislation permitting what is known as directed trusts, but in 2017, the Uniform Directed Trust Act was promulgated, seeking to provide a modicum of uniformity among the states, as wealth is now increasingly both interstate and international. Using the Uniform Directed Trust Act as a template, this Article discusses issues pertinent to directed trusts, …


Fiscal Federalism And The Fall Of Inheritance Taxes In The United States, Safia Sayed Sep 2025

Fiscal Federalism And The Fall Of Inheritance Taxes In The United States, Safia Sayed

ACTEC Law Journal

Modern scholars of American wealth transfer taxation underappreciate the system’s history—characterized at its incipience by a broad patchwork of state inheritance taxes rather than current law’s federal estate tax. Moreover, this history is not only neglected but incompletely recounted; in the last four decades of the twentieth century, a majority of states in all parts of the country suddenly and voluntarily dispensed with their inheritance taxes. This Article seeks for the first time to understand why, and in doing so, offers lessons to those attempting to optimally design a transfer tax system within a federalist system of governance. Through original …


Front Matter Mar 2025

Front Matter

ACTEC Law Journal

No abstract provided.


Unleashed Non-Grantor Trust Potential, Brent W. Nelson Mar 2025

Unleashed Non-Grantor Trust Potential, Brent W. Nelson

ACTEC Law Journal

No abstract provided.


Death And Debts, Kevin Bennardo Mar 2025

Death And Debts, Kevin Bennardo

ACTEC Law Journal

Uniform Probate Code section 2-606(a)(1) provides for automatic non-ademption of the unpaid purchase price of specifically devised property that was sold by the decedent after their will was executed but before their death. Rather than receiving the specific property that was left to them in the will, the named beneficiary receives the balance of any outstanding payments that are owed at the time of the decedent's death. This rule doesn't make sense. It doesn't square with the decedent's likely intent. The amount that the beneficiary will receive is largely arbitrary. It is tied to factors that have nothing to do …


Reform The Grantor Trust Rules, Jay A. Soled Mar 2025

Reform The Grantor Trust Rules, Jay A. Soled

ACTEC Law Journal

No abstract provided.


Silent Trusts And The Conflict Of Laws, Jeffrey Schoenblum Mar 2025

Silent Trusts And The Conflict Of Laws, Jeffrey Schoenblum

ACTEC Law Journal

No abstract provided.


Testamentary Freedom: A Constitutional Perspective, Richard J. Goralewicz Sep 2024

Testamentary Freedom: A Constitutional Perspective, Richard J. Goralewicz

ACTEC Law Journal

No abstract provided.


Front Matter Sep 2024

Front Matter

ACTEC Law Journal

No abstract provided.


Civilization Depends On Us: The Virtues Of Estate Planning And Estate Planners, Turney P. Berry Sep 2024

Civilization Depends On Us: The Virtues Of Estate Planning And Estate Planners, Turney P. Berry

ACTEC Law Journal

No abstract provided.


Constitutional Limitations On The Enforcement Of Foreign Forced Heirship Laws, Raquel Begleiter, Austin Bramwell, Molly Schiff Sep 2024

Constitutional Limitations On The Enforcement Of Foreign Forced Heirship Laws, Raquel Begleiter, Austin Bramwell, Molly Schiff

ACTEC Law Journal

No abstract provided.


Constitutional Limits On State Power To Tax Trust Income, Carlyn S. Mccaffrey, John C. Mccaffrey Sep 2024

Constitutional Limits On State Power To Tax Trust Income, Carlyn S. Mccaffrey, John C. Mccaffrey

ACTEC Law Journal

No abstract provided.


Why Do We Ask The Court To Do Something That It Can't? Constitutional And Practical Issues With Judicial Appointment Of Successor Trustees, R. Ethan Ward, Stephen C. Crofford Sep 2024

Why Do We Ask The Court To Do Something That It Can't? Constitutional And Practical Issues With Judicial Appointment Of Successor Trustees, R. Ethan Ward, Stephen C. Crofford

ACTEC Law Journal

No abstract provided.


Constitutional Issues In The Trusts And Estates Field Sep 2024

Constitutional Issues In The Trusts And Estates Field

ACTEC Law Journal

No abstract provided.


Anna Nicole's Constitutional Estates Law Legacy, Dave Fagundes Sep 2024

Anna Nicole's Constitutional Estates Law Legacy, Dave Fagundes

ACTEC Law Journal

No abstract provided.


After Sveen V. Melin, Is There A Contracts Clause Argument Against Laws Retroactively Terminating Child Support Obligations After The Death Of The Obligor Parent?, Diane Kemker Sep 2024

After Sveen V. Melin, Is There A Contracts Clause Argument Against Laws Retroactively Terminating Child Support Obligations After The Death Of The Obligor Parent?, Diane Kemker

ACTEC Law Journal

No abstract provided.


Front Matter Jun 2024

Front Matter

ACTEC Law Journal

No abstract provided.


Shakespeare, Succession, And Estate Planning:Lessons From The Bard, Leslie Kiefer Amann Jun 2024

Shakespeare, Succession, And Estate Planning:Lessons From The Bard, Leslie Kiefer Amann

ACTEC Law Journal

Probated in 1616, Shakespeare's Will is surprisingly relevant today. Two daughters survived him, but his only son died at age 11. Wife and daughters could not inherit a business in the theater, so he made changes in structure of the businesses he owned, and reallocated assets to accommodate the loss of his male heir. Shakespeare left no autobiographical information, but by examining his legal documents, we see him shift a thriving business, dependent on the unique talents and active participation of its founder, to passive assets in modified entity structures and generate an income stream for female descendants. Changes made …


The Dark Side Of Codifying U.S. Trust Law, Thomas P. Gallanis Jun 2024

The Dark Side Of Codifying U.S. Trust Law, Thomas P. Gallanis

ACTEC Law Journal

For most of Anglo-American history, trust law was case law. The law of trusts was born and molded in the English Court of Chancery and then re-shaped by the courts of the U.S. states. The U.S. law of trusts primarily was to be found in the decisions of state courts and in respected secondary sources digesting and refining the rules from those decisions, such as the American Law Institute's Restatements and the multi-volume treatises on trust law originally authored by Austin Wakeman Scott or George Gleason Bogert. U.S. trust law no longer is primarily case law. In 2000, the Uniform …


Towards A Review And Reform Of The Gst Tax:Symmetry Of Exemptions, The Reverse Gst Taxelection, And Consistent Inclusion Ratio Reporting, Stephen W. Murphy Jun 2024

Towards A Review And Reform Of The Gst Tax:Symmetry Of Exemptions, The Reverse Gst Taxelection, And Consistent Inclusion Ratio Reporting, Stephen W. Murphy

ACTEC Law Journal

No abstract provided.


Resolving Unfairness In A Fair Way: How The Grantor Trust Rules Should Be Reformed, Aaron T. Anderson Mar 2024

Resolving Unfairness In A Fair Way: How The Grantor Trust Rules Should Be Reformed, Aaron T. Anderson

ACTEC Law Journal

Affluent taxpayers often create one or more grantor trusts to achieve significant tax savings. By leveraging mismatches in the rules between the income and estate tax systems, these taxpayers avoid the compressed income tax brackets of trusts while minimizing the property that is included in their estates for estate tax purposes. Some commentators have argued that reform is needed to remove such mismatches. Yet, trusts that rely on the current grantor trust rules abound. This Note (1) provides a background and history of the rules and use of grantor trusts, (2) argues that harmonizing the estate and income tax systems …


The Importance Of Language In The Context Of Heirs' Property Policymaking, Molefi Mcintosh Mar 2024

The Importance Of Language In The Context Of Heirs' Property Policymaking, Molefi Mcintosh

ACTEC Law Journal

No abstract provided.


Policy Over Doctrine: A Brief History Of Us Trust Law, Lucas Clover-Alcolea Mar 2024

Policy Over Doctrine: A Brief History Of Us Trust Law, Lucas Clover-Alcolea

ACTEC Law Journal

US trust law is unique because whereas in English law the settlor drops out of the picture once he has created the trust, in the US the settlor’s intentions remain paramount. This fundamental difference in turn permits the recognition of spendthrift trusts, whereby the beneficial interest cannot be alienated, in the US whereas in England such trusts are generally invalid. Similarly, whereas in English law the beneficiaries of absolute trusts, and on occasion discretionary trusts, can collectively implode the trust by forcing the trustee to convey the trust fund to them via a Saunders v Vautier application, this is generally …


Unpacking The Digital Vault: Estate Planning Considerations For Non-Fungible Tokens, Ryan D. Tosto Mar 2024

Unpacking The Digital Vault: Estate Planning Considerations For Non-Fungible Tokens, Ryan D. Tosto

ACTEC Law Journal

The purpose of this article is to shed some light on the emerging, yet largely undefined, principle of openness in EU law. After addressing the semantic confusion existing between openness and transparency, it attempts, through a textual and systemic interpretation of their respective legal bases, to identify the normative content of the European Union's turn to openness. It then explores the principle s potential for attaining its declared Treaty-sanctioned objectives: promoting good governance and ensuring the participation of civil society in the democratic life of the Union. It illustrates that, although openness largely maintains an instrumental rationale, aimed at enhancing …