The economic substance doctrine /

"... analyzes the "economic substance doctrine" as codified in [section] 7701(o) of the Internal Revenue Code. Section 7701(o) defines the "economic substance doctrine" as the "common law" developed by the courts to disallow tax benefits for tax-motivated transacti...

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Bibliographic Details
Main Author: Chip, William W.
Corporate Author: Tax Management Inc
Other Authors: Keinan, Yoram
Format: Electronic Continuing Resource
Language:English
Published: Arlington, VA : Tax Management, [2006]-
Series:Tax management portfolios ; 508-2nd
Subjects:
Online Access:https://www.bloomberglaw.com/product/tax/citation/tm%20508
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Summary:"... analyzes the "economic substance doctrine" as codified in [section] 7701(o) of the Internal Revenue Code. Section 7701(o) defines the "economic substance doctrine" as the "common law" developed by the courts to disallow tax benefits for tax-motivated transactions that had no "business purpose" or no "economic substance." The "business purpose" test looks to the taxpayer's motives for entering into the transaction, while the "economic substance" test looks to the reality of the transaction. Prior to codification, the presence of either "business purpose" or "economic substance" was sufficient in some circuits to sustain a transaction's tax benefits (the "disjunctive" test); in other circuits both needed to be present (the "conjunctive test")
Item Description:Author: Yoram Keinan, <Sept. 27, 2007>-2015
Published: Washington, D.C., 2006-2007
Physical Description:1 online resource
Also issued in print
Publication Frequency:Updated irregularly
Format:Mode of access: World Wide Web
Bibliography:Includes bibliographical references