§2037, the Three-Year Rule, and the Consideration Exception

§§ 2036(a)(2) and 2038

Retained Enjoyment and Retained Control, §§ 2036 and 2038.

The Gross Estate, §§ 2031, 2033

In this episode, we will continue our discussion of completed gifts and also delve into valuing an interest in a trust.

In this episode, we will consider what constitutes a taxable gift.

In this episode, we will consider the foundations of the unified gift and estate tax.

For our fifth and final episode in the SALT series, we are going to discuss general principles of individual multi-state taxation, the use of the OSTC (other-state tax credit), and modern issues arising from the prevalence of remote work.

I hope you enjoyed this series. If there are any other subjects you would like me to cover, please let me know in the comments or by DM.

In Episode 4 of 5 in our SALT series, we will examine consumption taxes, such as sales and use taxes and related amalgamations thereof in this modern digital economy.

This is Episode 3 of 5 of our accelerated series on SALT (State and Local Taxation). Today we are tackling one of the most mechanically complex but conceptually fascinating areas of State and Local Tax: Apportionment and the Unitary Business Principle. We must answer the question: once a state has the constitutional authority to tax a multistate corporation, exactly how much of that corporation's income can it actually tax?