文章基本信息

标题：Gifts and the Income Tax—an Enduring Puzzle
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作者：Schmalbeck, Richard
期刊名称：Law and Contemporary Problems
印刷版ISSN：0023-9186
出版年度：2010
卷号：73
期号：1
页码：63-93
出版社：Duke Law
摘要：Schmalbeck explains that there are four policy options for the combined income tax treatment of a donor-donee pair, and that the best choice among the options is not self-evident. He notes that the current income tax treatment of noncharitable gifts originated with the 1913 income tax. The historical record provides no clues as to why Congress opted for that approach in 1913. As frustrating as this may be, it is an example of an important phenomenon in the development of the income tax. A number of crucial structural decisions made in the early days of the income tax, which continue to shape the current income tax, were made without any meaningful deliberation. He also provides an illuminating account of the income tax treatment of appreciation in gratuitously transferred property.
关键词：Income tax; Income taxes; Economic history; Donations; Gifts; Property rights; Fiscal policy; Gift tax