March 14, 2018

A Deemed Disclaimer

By Sanford J. Schlesinger and Andrew S. Auchincloss

One occasionally hears that a fruitful strategy for finding unusual opportunities and problems in the tax law is to focus on any provision in which an event is “deemed” to occur. The theory is that the “deemed” event greatly expands the potential for unintended consequences in the operation of the relevant Code section and that some of these unintended consequences may either benefit or harm taxpayers.

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