Tax Avatars

As avatars stand for the internet's end users, agents under a power of attorney act on behalf of the appointing principal. Both an avatar and an agent under a power of attorney are kinds of alter egos. The favorable wealth transfer tax treatment that legal avatars receive suggests their utility as a model for how the tax law could be expanded to recognize other choice-based relationships. In his novel The Partners, author and lawyer Louis Auchincloss wrote that ''[e]verything today is taxes. . . .

What better seat on the grandstand of life can I offer you than that of tax counsel? Understanding the tax treatment of legal avatars is the foundation for a grandstand for ~eeing the potential diversity ofpreference-based relationships that the law could embrace.