Attributes of Ownership

  title={Attributes of Ownership},
  author={Reid Thompson and D. Weisbach},
  journal={Public Economics: Taxation},
We examine the tax rules for ownership of fungible securities in light of three recent cases addressing this issue, Samueli, Calloway, and Anschutz. We argue that ownership has no economic basis under an income tax because under a pure income tax ownership would not be needed to measure income. Rather than acting as a bedrock principle based in economics, ownership in a realizationbased income tax acts as a default rule for assigning tax characteristics to positions. For example, ownership… Expand
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