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