One consequence of having graduated income tax rates is that it becomes advantageous to shift income from a high bracket taxpayer to a person in a lower tax bracket. A number of different vehicles have been tried to shift the incidence of the income tax to another person, and the courts and...

Tax reform and religion were two of the hot button issues during the last election. While at first glance these issues seem unrelated, a number of scholars have argued that religious values should guide our decisions regarding tax reform. This article posits that the relationship between...

Technology is revolutionizing our lives. With the touch of a button or a simple voice command, we can instantly order groceries, get directions, or find the nearest sushi restaurant. Sensibly, the private sector has capitalized on these recent innovations to drive up profits. To sell more...

Evident on both sides of the Tasman has been an increase in the use of trusts for tax planning purposes, brought about by high tax rates in the middle income ranges. This article seeks to answer why the trust is such a successful vehicle for income tax planning, discussing the scheme and...

With acknowledgment of the growing popularity of the trust as an effective taxation planning vehicle, this article explores various principles of taxing trusts under the Land and Income Tax Act 1956. The author first analyses the requirements of sections 155(a) and 155(b) of the Act and the...

Among government agencies, the IRS likely has the surest legal claim to the most information about the most Americans:their hobbies, religious affiliations, reading activities, travel, and medical information are all potentially tax relevant. Privacy scholars have studied the arrival of Big...

Federal tax law has long provided a tax benefit for charitable contributions of easements for conservation purposes. A fundamental problem with this conservation easement tax expenditure is that the measure for the tax benefit – lost economic development value – is erroneous. Use of such an...

The Protecting Americans from Tax Hikes (PATH) Act of 2015 was recently signed into law by the US President Obama, and one provision (section 126) in particular benefits venture capital, private equity, and other investors owning or planning to purchase a US corporation

Carried interest is the term used to describe a profits interest in a partnership that invests in entities. A managing partner typically will receive a 20% profits interest in exchange for managing the investments of the partnership. The complaint against the treatment of carried interest is...