Codifying Castle Harbour
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
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