For decades, policy makers and politicians have railed against the “tax gap,” or the difference between what taxpayers are legally obligated to pay in taxes and what they actually pay in taxes. To close the gap, Congress has instituted numerous reforms, with varying degrees of success....

In this report, the authors propose a limited carryover tax basis regime that would be restricted to marketable securities owned at death. They argue that their proposal would promote equity and raise an estimated $10 billion in annual revenue without raising tax rates

In yesteryear, at death, taxpayers confronted a Janus-faced tax system: on the one hand, they had to endure a harsh transfer tax regime that could significantly deplete the size of their estates; on the other hand, they could take solace in the fact that the income tax system erased their...

Technological advancements are playing a transformative role in curtailing the need for labor. These very same forces are catapulting capital in the form of robotics, machinery, and intellectual property to the economic forefront. In virtually every sphere of human existence, labor's decline and...

In a technological age, labor no longer plays the central role it once did in the nation's economy. Instead, automation has become more ubiquitous. This economic transformation has important and far-reaching consequences for the nation's tax system and, in particular, the means by which to fund...

The receipt of workplace fringe benefits has become increasingly ubiquitous. As a result of their employment, employees often receive a cornucopia of fringe benefits, including frequent-flier miles, hotel rewards points, rental car preferred status, office supply dollar coupons, cellular...

Mistakes occur in every profession, and attorneys practicing estate administration are not immune from this phenomenon. Funding marital trusts at the death of the first spouse engenders numerous opportunities for mistakes given the complex and technical nature of the tax law and the variety of...

Few things in the Internal Revenue Code (Code) are as enduring as the grantor trust rules. Housed in Subpart E of Subchapter J of the Code, they are essentially the same rules that were instituted by the so-called Clifford trust regulations promulgated over a half-century age. In instances where...