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...

Estates of U.S. decedents face an estate-tax filing requirement that is based exclusively on the size of the adjusted gross estate ("AGE"). If the AGE exceeds the threshold that applies in the year of the decedent's death $1,000,000 in 2002 a return must be filed, whether or not any estate tax...

The elevated exemption level under the federal transfer tax system (now in excess of $23 million for a married couple) has opened up new and abusive tax-avoidance opportunities. In many areas of the tax law, the substance over form doctrine historically has been effective in controlling such...

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

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...

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...