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Issues in Income Shifting

What’s past is prologue.

Examining the history of the back-and-forth between taxpayers and the Internal Revenue Service over income shifting helps us gain a clearer idea of what isn’t possible and what’s required to be able to shift income successfully today. Indeed, some techniques that seemingly were eliminated might not be dead yet, as we’ll see. I won’t be discussing any international tax or consolidated return issues, other than to acknowledge that there are income-shifting benefits in many of these arrangements


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