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- Title
Circular Cash Flows and the Federal Income Tax.
- Authors
CUMMINGS JR., JASPER L.
- Abstract
The article discusses the treatment of circular cash flows by the federal judiciary in the United States. The article examines various circular cash flows, including transactions between a taxpayer and itself in the form of an agent and instances where pairs of separate exchanges are treated as one because they are not generated by two separate relationships. The author claims that due to misapplication of step transaction analysis that takes a substance over form approach to transactions, the judiciary ignores the passage of cash in almost all cases where cash winds up where it began. The author argues that this approach often misses circumstances in which the cash’s passage should not be ignored.
- Subjects
UNITED States; TAXATION of cash flow; STEP transaction doctrine; SUBSTANCE over form doctrine; INTERPRETATION &; construction of American law; INCOME tax
- Publication
Tax Lawyer, 2011, Vol 64, Issue 3, p535
- ISSN
0040-005X
- Publication type
Article