Going Non-Vertical With Fund Interests

The vagaries and draconian nature of Internal Revenue Code Section 2701 have understandably led to widespread deference to the vertical slice rule. However, it is essential to bear in mind that the vertical slice isn't actually a rule, but rather one of a number of exceptions to the application of Section 2701. When adherence to the vertical slice exception isn't feasible or would produce an undesirable

The vagaries and draconian nature of Internal Revenue Code Section 2701 have understandably led to widespread deference to the “vertical slice rule.” However, it is essential to bear in mind that the “vertical slice” isn't actually a rule, but rather one of a number of exceptions to the application of Section 2701. When adherence to the vertical slice exception isn't feasible or would produce an undesirable result for your client, you should consider alternative approaches.

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