DEATH TAXES ON COMPLETED TRANSFERS INTER VIVOS

The subjection of transfers inter vivas to the death tax under each of the above categories has been based upon the proposition that, for a transfer inter vivas properly to be subject to the death tax, it must bear some reasonable relationship to transfers at death either by will or under the law relating to intestacy. This rule has been applied both in problems of statutory construction and in problems of constitutionality. The recent decision of the United States Supreme Court in Helvering v. Bullard seems to have abandoned this test for the inclusion of transfers inter vivas within the scope of the death tax, so far as the federal death tax is concerned. It is the purpose here to study the present status of the law relating to death taxes upon transfers inter vivas, with particular reference to the taxation of such transfers complete when made, as upheld by this Supreme Court decision.