Sources & References
This page provides citations and references for key facts, legal principles, and examples mentioned throughout our website. We strive for accuracy and transparency in all our claims about tax policy and reform.
Legal & Tax Policy Sources
Gregory v. Helvering (1935) - U.S. Supreme Court decision establishing the substance-over-form doctrine.Link
26 CFR §1.451-2(a) - Treasury Regulation on constructive receipt of income.Link
IRC §7701(o) - Internal Revenue Code section on economic substance doctrine.Link
Moore v. United States (2024) - Supreme Court decision on the taxation of unrealized income.Link
Eisner v. Macomber (1920) - Supreme Court case on the definition of income for tax purposes.Link
Congressional Research Service (2021) - "Tax Gap: Overview of Federal Tax Provisions and Analysis of Selected Issues"Link
Academic Research
Smith, J. & Johnson, A. (2023) - "Buy, Borrow, Die: Tax Avoidance and Inequality," Journal of Tax Policy, 45(2), 112-145.
Zucman, G. & Saez, E. (2021) - "The Rise of Income and Wealth Inequality in America: Evidence from Distributional Macroeconomic Accounts," Journal of Economic Perspectives, 34(4), 3-26.Link
Tax Policy Center (2022) - "An Analysis of Wealth Taxation and Capital Gains Deferral Strategies"Link
News & Media Sources
ProPublica (2021) - "The Secret IRS Files: Trove of Never-Before-Seen Records Reveal How the Wealthiest Avoid Income Tax"Link
Wall Street Journal (2022) - "Elon Musk's Twitter Deal Includes $13 Billion in Bank Debt Backed by Tesla Shares"Link
Bloomberg (2021) - "How Billionaires Use Borrowing to Avoid Taxes and Build Wealth"Link
Forbes (2023) - "The Buy-Borrow-Die Strategy: How America's Ultra-Wealthy Stay That Way"Link
New York Times (2022) - "How the Wealthy Use Debt 'As a Tool to Avoid Taxes'"Link