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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Corporate Author: | |
Other Authors: | |
Format: | Online |
Language: | English |
Published: |
Arlington, VA :
Tax Management,
[2006]-
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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") |
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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 |