Vanderbilt Law Review


Allen T. Malone

First Page



The purpose of this note is to examine the present tax treatment of the three most popular income splitting devices used to avoid taxes: the family partnership, multiple trusts, and multiple corporations. In Part II, the various congressional and judicial limits and sanctions imposed upon these devices will be discussed along with recently proposed regulatory legislation. Part III will consist of an evaluation of the suggested limitations upon the use of income splitting devices. The ultimate concern of this note is to arrive at some conclusions as to the general approach and the specific methods best suited (1) to regulate what are often deemed "sham" devices to split income and thus avoid taxes, and at the same time (2) to reduce the great amount of uncertainty and confusion which now exists in this field.

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Tax Law Commons