Tax Shelters - Past, Present and Future
Date:
November 20 2003
The Past
Tax shelters have been with us since the 1972 tax reform.1 In the early days, life was relatively simple — personal tax shelters were partnerships (movies, aircraft), and corporate shelters were largely concerned with ‘‘surplus stripping’’ (pre-1972 capital appreciation and retained earnings) or loss transfers. There were no ‘‘at-risk’’ rules, no leasing property rules, no equivalent to subsection 69(11), and, of course, no GAAR.
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