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Codifying Castle Harbour

5 Pages Posted: 7 Mar 2016 Last revised: 8 Sep 2016

Karen C. Burke

University of Florida - Levin College of Law

Grayson M. P. McCouch

University of Florida - Levin College of Law

Date Written: January 4, 2016

Abstract

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

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

Karen Burke (Contact Author)

University of Florida - Levin College of Law ( email )

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

Grayson McCouch

University of Florida - Levin College of Law ( email )

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

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