Issues in Income ShiftingIssues in Income Shifting

Examining the history of the back-and-forth between taxpayers and the Internal Revenue Service over income shifting helps us gain a clearer idea of what isn’t possible and what’s required to be able to shift income successfully today. Indeed, some techniques that seemingly were eliminated might not be dead yet, as we’ll see. I won’t be discussing any international tax or consolidated return issues, other than to acknowledge that there are income-shifting benefits in many of these arrangements.

What’s Income Shifting?

Income shifting is the reallocation of taxable income from a taxpayer who’s in a high income tax bracket to a taxpayer who’s in a lower income tax bracket. Typically, the shift of income is from parent to child but can be from...