Start of Main Content
Article
The Problematic Delta Test for Dividend Equivalents
Tax Notes
Author(s)
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.