Sullivan
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Carole Bass and Amy Sheridan, partners at Sullivan & Worcester, co-authored an article with Cara Koss titled "Taxes and Personhood: States’ Evolving Definitions of Person," published by Tax Notes Federal [subs. req'd] on November 21, 2025. The article analyzes the evolving definitions of personhood in state laws and their implications for federal tax law, particularly in light of recent judicial decisions and legislative changes. ​

Topics of the article include:

  • State Personhood Laws and Their Variability ​
  • Internal Revenue Code and Definitions of Person ​
  • Case Law and Historical Precedents
  • IRS Guidance and the Born Alive Requirement ​
  • Implications of State Personhood Laws ​
  • Federal Tax Implications of Evolving Definitions ​
  • Transfer Tax Considerations