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Author(s)

Thomas Joseph Brennan

Robert L. McDonald

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