Title
Microsoft Word - DiCarlo Vol 45 No 2 Summer 2010.doc
By
alyneh
Description
WHAT ESTATE PLANNERS NEED TO KNOW ABOUT THE STEP TRANSACTION DOCTRINE Donald P. DiCarlo, Jr.∗ Editors’ Synopsis: In this Article, the Author discusses the courts’ recent use of the step transaction doctrine to develop the new standards of “real economic risk” and “tax-independent significance” for evaluating whether the steps in an estate planning transaction should be collapsed. The Author asserts that estate planners may need to expand their roadmap for avoiding IRS challenges to transactions...

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