New Prominence of Tax Basis in Estate Planning

7 Pages Posted: 11 Apr 2016 Last revised: 26 May 2016

See all articles by Paul L. Caron

Paul L. Caron

Pepperdine University - School of Law

Jay A. Soled

Rutgers University

Date Written: March 28, 2016


In this article, Caron and Soled discuss how section 1014(b)(6) offers a bridge for taxpayers to maximize the tax basis they have in their assets. Whether Congress should retain this anachronistic provision is an open issue. The authors explain the historical background of section 1014(b)(6), demonstrate the potential income tax savings from applying it, and outline several planning strategies to achieve those savings.

Keywords: Tax, Estate Planning, Estate Tax, Income Tax, Basis

JEL Classification: K34

Suggested Citation

Caron, Paul L. and Soled, Jay, New Prominence of Tax Basis in Estate Planning (March 28, 2016). Tax Notes, Vol. 150, p. 1569, Mar. 28, 2016; Pepperdine University Legal Studies Research Paper No. 16. Available at SSRN:

Paul L. Caron (Contact Author)

Pepperdine University - School of Law ( email )

24255 Pacific Coast Highway
Malibu, CA 90263
United States
310.506.4266 (Phone)

Jay Soled

Rutgers University ( email )

1 Washington Park
Newark, NJ 07901-1825
United States
(973) 353-1727 (Phone)

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