Federal Income Tax Project

From 1960 through 1999, the Institute published a series of Studies and Reports addressing a variety of issues on the United States Tax Code. Reporters tackled Estate and Gift Tax, Generation-Skipping Transfers, and Subchapters C, J, and K, as well as International Aspects of Income Tax and the Taxation of Private Business Enterprises.  Their observations and recommendations are collected here.

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    International Aspects of the United States Income Taxation
    499 pages, 1987, #5897

    Part of the Institute’s Federal Tax Project, this work addresses structural questions involved in applying the federal income tax in an international context..Focusingon  both foreign persons and the foreign income of United States person, the study contributed directly to the development of several provisions that were included in the Tax Reform Act of 1986. 

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    Subchapter C: Proposals on Corporate Acquisitions and Dispositions and Reporter’s Study on Corporate Distributions
    551 pages, 1985, #5650

    Part of the Institute’s Federal Tax Project, this work combines a thorough analysis and critique of the current tax law governing transactions among corporations and their investors with carefully worked out proposals for eliminating present inconsistencies and inequities. The proposals call for substantial change in the tax treatment of corporate acquisitions and dispositions and reflect a wide consensus in support of the elimination of the hyper-technical and easily manipulated reorganization provisions of law.

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    Subchapter J: Proposals on the Taxation of Trust and Estate Income and Income in Respect of Decendents
    148 pages, 1985, #5796

    Part of the Institute’s Federal Tax Project , this work is primarily concerned with reducing the availability of the private trust as a tax shelter for the wealthy while preserving its use as a means of providing prudent management of assets for the benefit of those who cannot satisfactorily manage the assets themselves. Among the innovations proposed are elimination of the complicated "throwback" rule and tier system of present law, the consolidation for tax purposes of multiple trusts established by a single creator, and the taxation of income to the trust in specified situations during the creator’s lifetime at the creator’s marginal rate

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    Subchapter K: Proposals on the Taxation of Partners
    592 pages, 1984, #5695

    Part of the Institute’s Federal Tax Project , this work includes multiple proposals on the taxation of partners. The unifying thesis for the book is that the income of a partnership should, so far as feasible, be taxed to the partners as though each of them was directly conducting his or her proportionate share of the partnership business. While countervailing factors may call for deviation from this "pass through" model, much of the book is devoted to appraising the adequacy of the reasons for particular departures, both those presently in force and those proposed.

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    Study on Generation-Skipping Transfers Under the Federal Estate Tax
    206 pages, 1984, #5728

    Part of the Institute’s Federal Tax Project, this work was a response to calls for repeal of the tax on certain generation-skipping transfers. Extensive in scope, the Study took an objective look at the equity, efficacy and administrability criteria of this tax.

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    Federal Estate and Gift Taxation
    589 pages, 1969, #5050

    Part of the Institute’s Federal Tax Project, this work provides Reporters’ recommendations focused on Estate and Gift Tax provisions. It also includes historical studies, evaluations, and criticisms of dual tax and unified tax systems, as well as accessions tax system.

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    Federal Income, Estate and Gift Tax
    511 pages, 1960, #5055

    Part of the Institute’s Federal Tax Project, this work is a discussion draft addressing problems in capital gains taxation.

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    Taxation of Private Business Enterprises
    496 pages, 1999, #6135

    Part of the Institute’s Federal Tax Project , this work explores the consequences of the flexibility presently available to owners of private business enterprises to determine how their businesses should be classified for federal income-tax purposes, and thus the extent of their income-tax liability. It sets forth a coherent set of specific proposals and recommends that current law should be replaced by a system whereby all private business firms would be taxed as conduits for income-tax purposes, with tax liability passed through the csompany to the individual owners.

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