Howard Abrams
From Emory University School of Law, Atlanta, USA
The Section 734(b) Basis Adjustment Needs Repair
The partnership tax provisions – Subchapter K of the Internal Revenue Code – work pretty well. And they have a difficult job to do because they must provide a reasonable mechanism for taxing arrangements between parties that can be far from off-the-rack. It should not be difficult to figure out how to tax two individuals [...]
A Technical Analysis of Proposed Section 710
I. Introduction Representative Charles B. Rangel (D-NY), Chairman of the House Committee on Ways and Means, introduced on October 25, 2007, a comprehensive tax reform bill (H.R. 3970) which includes proposed new section 710 of the Internal Revenue Code. This provision also has been included in the Temporary Tax Relief Act of 2007 (H.R. 3996), [...]
