Beckett G. Cantley (St. Thomas University) has published Congress Giveth and Congress Taketh Away: The Slow Death of the SESOP, 20 Akron Tax J. 59 (2005). Here is part of the Introduction:
[T]he SESOP has been a very rich source of tax gamesmanship since its inception. However, while Congress and the Service have been very effective at closing all the perceived loopholes, they have equally been extremely adept at dismantling the SESOP as a viable planning vehicle for the average small family business. This article discusses in detail each of the SESOP skirmishes mentioned above and outlines the practical effect of the outcome of each of them.



