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 transactio...
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| Previous Title: | Keinan, Yoram The economic substance doctrine |
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| Main Author: | |
| Corporate Authors: | , |
| Other Authors: | |
| Format: | Book |
| Language: | English |
| Published: |
Arlington, VA :
Tax Management Inc.,
2015
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| Series: | Tax management portfolios ;
508-2nd |
| Subjects: | |
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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")."--Page iii |
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| Item Description: | "Bloomberg BNA"--Cover "Based on an ealier version by Yoram Keinan, Esq." "revises and supersedes 508 T.M." |
| Physical Description: | 1 volume (loose-leaf) : ill. ; 28 cm |
| Publication Frequency: | Updated irregularly |
| Bibliography: | Includes bibliographical references (pages C-1-C-2) |
| ISBN: | 9781633590786 163359078X |