Theodore D Setzer Special Counsel IRS Office of Associate Chief Counsel (International) gives us an IRS view of tax avoidance
Given the amount of ink that has been spilled about the recent wave of economic substance decisions by United States courts one might think that the doctrine of economic substance is a new development. In recent months courts have handed down decision after decision holding that transactions did not have the substance necessary to sustain the claimed tax benefits. For example Coltec Industries Inc v United States 454 F.3d 1340 (Fed. Cir. 2006) cert. denied 2007 U.S. LEXIS 2087 (2007) and Black and Decker Corp v United States 436 F.3d 431 (4th Cir. 2006). Both involved a type of transaction designed to create...
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Theodore D Setzer Special Counsel IRS Office of Associate Chief Counsel (International) gives us an IRS view of tax avoidance
Given the amount of ink that has been spilled about the recent wave of economic substance decisions by United States courts one might think that the doctrine of economic substance is a new development. In recent months courts have handed down decision after decision holding that transactions did not have the substance necessary to sustain the claimed tax benefits. For example Coltec Industries Inc v United States 454 F.3d 1340 (Fed. Cir. 2006) cert. denied 2007 U.S. LEXIS 2087 (2007) and Black and Decker Corp v United States 436 F.3d 431 (4th Cir. 2006). Both involved a type of transaction designed to create...
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