Logo Logo

The Problematic Delta Test for Dividend Equivalents, Tax Notes

Abstract

The delta test in prop. reg. section 1.871-15 can be affected by superficial labeling. We propose improved alternatives, but also show that game playing remains possible if administrative constraints impose limits, such as allowing only one-time evaluation of instruments.

Type

Article

Author(s)

Thomas Joseph Brennan, Robert L. McDonald

Date Published

2015

Citations

Brennan, Joseph Thomas, and Robert L. McDonald. 2015. The Problematic Delta Test for Dividend Equivalents. Tax Notes. 146(4): 525-532.

KELLOGG INSIGHT

Explore leading research and ideas

Find articles, podcast episodes, and videos that spark ideas in lifelong learners, and inspire those looking to advance in their careers.
learn more

COURSE CATALOG

Review Courses & Schedules

Access information about specific courses and their schedules by viewing the interactive course scheduler tool.
LEARN MORE

DEGREE PROGRAMS

Discover the path to your goals

Whether you choose our Full-Time, Part-Time or Executive MBA program, you’ll enjoy the same unparalleled education, exceptional faculty and distinctive culture.
learn more