Earlier quoted context omitted.
That is easy. If they claim the contract-encumbered work is worth 0 dollars for tax reasons, then anybody (who does not intend to commit breach of contract) should be allowed to buy the fully encumbered work for 0 dollars and the original owner can take the loss/write-off. That should get like the central 90% of cases. Probably need some fine-tuning to get the rest and reduce opportunities for abuse (maybe some minim…
I create multiple movies, one works well and I think to myself I pay too much taxes this year. I sell the next one for 0 dollars to my cousin so I can write it off immediately. If the movie works, money stays in the family, if it doesn't I already got deductions and it was a no-op for my cousin.
Can you try to spend 30 seconds countering whatever problems you came up with and only then propose non-trivial problems? I promise I gave the idea more than 30 seconds of thought and did think of the obvious problems, it is just tiring to exhaustively list out and pedantically enumerate a complete proposal instantiated for this specific domain. That is also why I explicitly said it solves the central 90% and would require tuning and mechanisms to reduce abuse since I do, in fact, know the proposal is incomplete, just that the problems I am aware of with this class of solution generally appear to be quite amenable to solutions that should be at least as robust as the status quo.