Taxing Partnership Profits Interests: The Carried Interest Problem
Vol. 124 No. 7
Taxation
Intermountain Insurance Service of Vail, LLC v. Commissioner
Federal Tax Court Holds Pre-Chevron Judicial Construction of Statute Precludes Subsequent Agency Interpretation if Prior Construction Was Premised on Legislative History.
Vol. 124 No. 4
Department of Revenue of Kentucky v. Davis
Vol. 122 No. 1
Taxing Private Equity Carried Interest Using an Incentive Stock Option Analogy
Vol. 121 No. 3
Equal Opportunity and Inheritance Taxation
Vol. 121 No. 2
Equality of opportunity is understood to be one of the bedrock principles
supporting the taxation of inheritance. The familiar idea is that
inherited wealth offers an unjustified head start for some individuals at
the expense of others. In political theory, this principle is closely identified
with the branch of liberalism known as resource equality. But the
resource equality ideal has not been fully translated into the legal literature.
The major legal writings on inheritance taxation use the term
“equal opportunity” quite generally and often blend equal opportunity
with goals that are distinct, like wealth equalization.
This Article revisits the topic of inheritance taxation