Three transfer tax minimization mechanisms—zeroed-out grantor retained annuity trusts (GRATs), intentionally defective grantor trusts (IDGTs), and family-controlled entities with steep valuation discounts—significantly shrink the federal estate and gift tax base. This white paper explains...

The “tax gap”—the difference between the amount of “true tax” and the amount of tax actually paid—has garnered widespread attention in recent months. Much of the commentary on the subject equates the tax gap with “tax evasion,” a term broadly understood to connote intentional...

This document, prepared as a response to a Question for the Record from House Ways & Means Subcommittee on Oversight Chair Bill Pascrell, explains how previous actions by Treasury and the IRS have facilitated strategies that allow high-net-worth individuals and families to exploit stepped-up...

[This testimony was delivered on December 8, 2021, to the House Committee on Ways and Means, Subcommittee on Oversight, as part of a hearing on "The Pandora Papers and Hidden Wealth."]The US is the world’s leading investment destination for offshore wealth. Our laws enable foreigners—through...

The equality-equity dilemma in cost-benefit analysis arises when regulators seek to advance distributional objectives through lifesaving rules. The “equality” side of the equality-equity dilemma refers to the federal regulatory practice of using an equal-dollar “value of a statistical...

The Senate Finance Committee’s hearing on July 28, 2021 -- "Building on Bipartisan Retirement Legislation: How Can Congress Help?" -- spotlighted “mega-IRAs”: individual retirement accounts with balances of $5 million or more. An analysis by the Joint Committee on Taxation in advance of...

The conventional explanation for controversy over climate change emphasizes impediments to public understanding: Limited popular knowledge of science, the inability of ordinary citizens to assess technical information, and the resulting widespread use of unreliable cognitive heuristics to assess...

Patents claiming DNA sequences have been subject to extensive public and scholarly criticism due to their potential to impede innovation and to restrict access to affordable healthcare. Recent empirical studies, however, indicate that access to materials is a much more serious problem than...