5 Pages Posted: 7 Mar 2016 Last revised: 8 Sep 2016
Date Written: January 4, 2016
In this article, Burke and McCouch discuss the 2015 statutory amendment, enacted as part of the last-minute budget deal, that revised and renumbered the family partnership provision of section 704(e)(1). They question whether the change will accomplish its stated purposes of clarifying existing law and raising $1.9 billion in revenue, and they conclude that the 2014 proposals by former House Ways and Means Committee Chair Dave Camp offer a politically expedient source of selective pay-fors for future government spending without actually raising taxes.
Keywords: Castle Harbour, Bipartisan Budget Act of 2015, family partnerships, tax shelters
Suggested Citation: Suggested Citation
Burke, Karen C. and McCouch, Grayson M. P., Codifying Castle Harbour (January 4, 2016). 150 Tax Notes 109 (2016); University of Florida Levin College of Law Research Paper No. 16-27. Available at SSRN: https://ssrn.com/abstract=2742180