The proposal aims to simplify the law pertaining to transfers with retained interests and powers under the estate and gift tax that are potentially within current IRC sections 2036-2038. Under the proposal, transfers with retained current-enjoyment interests would be deemed to be incomplete...

Suppose a parent “loans” her vacation home “Dellview” in Aspen to her adult child for a non-specified period of time without rent or other charge for the use of the property. The home has a rental value of $1,000 per day. There is no formal lease agreement. Therefore, the parent (as...

This article proposes replacing the federal estate and gift tax system with an accessions tax. An accessions tax is a tax, at progressive rates, on the aggregate lifetime gratuitous receipts of an individual in excess of a specified exemption. The main thesis of this article is that an...

This article argues that the classic Haig-Simons formulation of personal income, namely, an individual’s consumption plus net increases in wealth for the taxable year, was not actually embraced by Simons himself, is contrary to fundamental political values, and (unnecessarily) raises...

The thesis is that inconsistent tax accounting rules undermine the individual income tax, and the best available move for improving it – given the unassailability of the realization principle - is to eliminate its accrual (and quasi-accrual) features. Specifically, the agenda is to eliminate...

The idea advanced herein, as a thought experiment, is the possibility of expanding (by legislation) – or possibly interpreting (by Treasury regulation) – section 265(a)(1) to disallow deductions deemed to have paid out of tax-exempt (i.e., excluded) income. Although section 265(a)(1) already...

This essay considers the benefit, partnership, and ability to pay principles of tax justice with respect to their foundations and how they bear (if at all) on such issues as the role and size of government, the choice of the tax base, and the structure of rates and exemptions. The method of...