Interpretative theory and tax shelter regulation.

Virginia Tax Review;  September 22, 2006 ;     700+ words ......The foremost of these tools, the economic substance doctrine, is a common law rule (3...decisions in which courts read the economic substance doctrine narrowly, if they are willing...Even Knetsch, tax law's most famous economic substance loser, (10) might try his deal with...

A Review of the Economic Substance Doctrine

Stanford Journal of Law, Business & Finance;  October 1, 2004 ;     700+ words ......over form," "business purpose," and "economic substance" have been used for more than seventy...recharacterization"; and (3) the "economic substance doctrine."4 The first method of disallowance...form because the transaction lacks economic substance. This method is called the ...

When and How Should the Economic Substance Doctrine Be Applied?

Tax Law Review;  October 1, 2006 ;     700+ words ......and found that there is still an economic substance doctrine,2 but it applied the doctrine...step lacked business purpose and economic substance when considered on its own. "[T]he...tax-independent business purpose or economic substance. But such an exercise does little...

Congress continues to focus on tax-shelter activity.(washington insights)

Financial Executive;  November 1, 2007 ;     700+ words ......legislative proposals to codify the economic substance doctrine, and to punish companies...activities in tax haven countries. The economic substance doctrine is not new. U.S. tax courts...and subsequently developed--both an economic substance test and a business purpose test...

Rep. Doggett Introduces Abusive Tax Shelter Shutdown, Taxpayer...

US Fed News Service, Including US State News;  June 1, 2007 ;     700+ words ......transactions without substantial economic substance." The bill, introduced on May 16...transactions without substantial economic substance, and for other purposes.Be it enacted...SHELTERSSec. 101. Clarification of economic substance doctrine.Sec. 102. Modification of...

"Economic Substance": Drawing the Line Between Legitimate Tax Minimization...

Canadian Tax Journal;  January 1, 2006 ;     593 words ......this article, the author argues that economic substance is a useful standard for drawing...interpretation. Moreover, the author argues, economic substance is the best method for balancing...also recognized the relevance of economic substance in the recent Canada Trustco decision...

Committee on Taxation.(FEI TECHNICAL COMMITTEES)

Financial Executive;  July 1, 2007 ;     141 words ......legislative proposal to codify the judicially created economic substance doctrine. The proposal will likely provide that a transaction has economic substance (and thus satisfies the economic substance doctrine) only if the taxpayer establishes...

Tax sham or prudent investment: deconstructing the government's pyrrhic...

Virginia Tax Review;  September 22, 2002 ;     700+ words ......these transactions as lacking real economic substance and contended that Salina could not...transaction did contain sufficient economic substance to be respected for taxation purposes...law governing tax shelters -- the economic substance doctrine. This part will examine...

Where U.S. company tries to reduce its tax liability through transactions...

International Law Update;  October 1, 1999 ;     63 words ......American Depository Receipts (ADRs) lacked economic substance and that the company was liable for an accuracy-relat...of first impression, the Court applies the economic substance doctrine to a foreign tax credit issue.

Creditable foreign taxes and the US economic substance profit test.

Australasian Business Intelligence;  February 22, 2007 ;     170 words ......relation to the application of what is referred to as the economic substance profit test. It has been suggested that a result of the...taxes should be treated as an expense when applying the economic substance profit test base their argument on the apparent flawed...

Treasury rules on LILO revenue

Equipment Leasing Today;  April 1, 1999 ;     150 words ......incurred in connection with a LILO transaction that lacks economic substance". As for enforcement, "the Service will scrutinize LILO transactions for lack of economic substance and/or, in appropriate cases, recharacterize transactions...

PwC U.S. Chairman calls for balance between rules and...

Financial Executive;  March 1, 2006 ;     700+ words ......accounting really reflecting the economic substance of a transaction? He believes that...premise is to reflect the underlying economic substance of a leasing arrangement between...but have you really satisfied the economic substance of a given transaction? Whereas...

FLPs as estate planning tools.(family limited partnerships)

The Tax Adviser;  December 1, 2002 ;     577 words ......2002-246, in which a FLP had little economic substance. Facts After meeting with financial...a), arguing that the FLPs lacked economic substance and that their activities were limited...only a recycling of value without economic substance. Although a few investments had been...

US tax lawyers criticize Senate's tax reconciliation bill.

Australasian Business Intelligence;  February 26, 2006 ;     165 words ......Tax Review - ABIX via COMTEX) -- The codification of the economic substance doctrine in the US tax reconciliation legislation may...for understatements attributable to transactions lacking economic substance. Publication Date: February 2006 AMERICAN BAR ASSOCIATION...

Rep. Holt Introduces Nonitemizer Real Property Tax Deduction Act

US Fed News Service, Including US State News;  September 25, 2006 ;     700+ words ......31, 2006.SEC. 3. CLARIFICATION OF ECONOMIC SUBSTANCE DOCTRINE.(a) In General- Section...subsection:`(o) Clarification of Economic Substance Doctrine; etc-`(1) GENERAL RULES...which a court determines that the economic substance doctrine is relevant for purposes...