Unified Passthrough Reform Misses the Mark

15 Pages Posted: 6 May 2015 Last revised: 29 Sep 2015

See all articles by Karen C. Burke

Karen C. Burke

University of Florida Levin College of Law

Date Written: March 16, 2015


This article considers recent proposals to replace subchapters K and S with a unified passthrough system. It argues that resistance to a unified approach may pave the way for further expansion of subchapter S and discusses proposed fixes to the section 1374 tax on built-in gains. The article suggests that proposed mandatory basis adjustments under subchapter K, unless coupled with partial liquidation treatment, would introduce needless complexity. Finally, the article considers the possibility of eliminating subchapter K and expanding subchapter S to include as many privately held businesses as possible.

Keywords: Camp proposals, partnerships, S corporations, employment taxes, 1374 tax, mandatory basis adjustments, corporate tax reform

JEL Classification: K34

Suggested Citation

Burke, Karen C., Unified Passthrough Reform Misses the Mark (March 16, 2015). Tax Notes, Vol. 146, 2015, University of Florida Levin College of Law Research Paper No. 15-10, Available at SSRN: https://ssrn.com/abstract=2602766 or http://dx.doi.org/10.2139/ssrn.2602766

Karen C. Burke (Contact Author)

University of Florida Levin College of Law ( email )

P.O. Box 117625
Gainesville, FL 32611-7625
United States

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