The Income Tax Collapse

Edward McCaffery is the Robert C. Packard Trustee Chair in Law and Professor of Law, Economics, and Political Science at the University of Southern California Law School (USC). Ed coined the phrase "Buy, Borrow, Die" in the 1990s to help his students understand deep structural features of income tax law. He has written many books, articles, and popular commentaries, as on CNN. He is also the cofounder, with his daughter Sabrina, of the People's Tax Page (www.peoplestaxpage.org) which explains tax policy in cartoons and other media for ordinary people. David Gamage is the Law School Foundation Distinguished Professor of Tax Law & Policy at the University of Missouri School of Law. He is ranked among the top ten most-cited US tax law scholars [Brian Leiter & Sisk/Catlin/Anderson/Gunderson Rankings] and among the top twenty-five all-time law authors on the Social Science Research Network [SSRN Top 3,000 Law Authors; as of October 31, 2024] and as the third all-time tax law professor[Paul Caron/TaxProf Blog SSRN Tax Professor Rankings]. David has written extensively on tax policy and public finance, and has worked with lawmakers on reform proposals to address the problems of "Buy, Borrow, Die". He has testified before the US Congress and state legislatures, and his research on wealth and income tax reforms has been cited by the US Supreme Court.

• Introduction Part I. Beginning 1: Buy Borrow Die and Beyond Part II. Understanding 2: Inclusions in the Tax Base: What Is Income? 3: Subtractions from the Tax Base 4: Timing 5: Attribution 6: Characterization of Ordinary Income and Capital Gains Part III. Planning 7: Work: Planning for Wage Earners 8: Walling off Work: The Rise and Fall of Tax Shelters 9: Planning for Businesses and Businesspeople (Active Buy Borrow Die) 10: Planning for the Wealthy (Passive Buy Borrow Die) Part IV. Reforming 11: Fixing Buy Borrow Die 12: Last Words