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- Title
THE FRAME GAME: HOW DEFINING THE \"TRANSACTION\" DECIDES THE CASE.
- Authors
Hariton, David P.
- Abstract
The author discusses the issue of structuring a financial transaction that allows the taxpayers to mitigate taxes that would otherwise have been paid. He argues against the approach of the U.S. Internal Revenue Service (IRS) towards using the tax shelter label as a tool in its litigation arsenal to help win its case in the court. He suggests that while defining the relevant transaction the IRS should consider it as the mere contribution of the relevant assets to a special purpose entity.
- Subjects
UNITED States; UNITED States tax laws; UNITED States. Internal Revenue Service; TAX shelters; ASSETS (Accounting); TAX planning; SPECIAL purpose entities (Corporations)
- Publication
Virginia Tax Review, 2011, Vol 31, Issue 2, p221
- ISSN
0735-9004
- Publication type
Article