Document Type

Article

Publication Date

2-17-2003

ISSN

1048-3306

Publisher

Tax Analysts

Language

en-US

Abstract

To shut down a particular kind of offshore tax shelter scheme regarded as abusive, the Treasury has proposed changes in the way shareholders recover investment after engaging in corporate redemptions taxed as dividends. This article argues that the proposed regulations operate poorly in the more typical setting of distributions by corporations to individual shareholders, that existing law produces better results in those situations, and that the Treasury should employ narrower rules to attack tax shelter arrangements.

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