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- Title
Sometimes Unguided (or Maybe Misguided) Economic Substance Guidance.
- Authors
Jensen, Erik M.
- Abstract
This article discusses newly issued guidance about key issues in Section 7701(o), the codification of the economic substance doctrine, and the associated penalty provision in Section 6662(b). In particular, Notice 2014-58 discusses the meaning of the statutory terms "transaction" and "similar rule of law." Although guidance about the meaning of key terms and concepts is always welcome, the new notice, which amplifies Notice 2010-62 (also discussed and criticized in the article), is not as helpful as it might have been.
- Subjects
SUBSTANCE over form doctrine; TAX laws; TAX accounting -- Law &; legislation; RULE of law; CODIFICATION of law
- Publication
Journal of Taxation of Investments, 2015, Vol 32, Issue 2, p27
- ISSN
0747-9115
- Publication type
Article