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

Financial Executive;  November 1, 2007 ;   Prysock, Mark;   787 words ......proposals to codify the economic substance doctrine, and to...countries. The economic substance doctrine is not...are engaging in business transactions for...developed--both an economic substance test and a business purpose test. Congressional...Committee, the ...

Under the watchful eye of state tax administrators: the business-purpose...

The Tax Adviser;  September 1, 2002 ;   Nakamura, Karen M. Hogroian, Ferdinand;   787 words ......conjunction with a business-purpose and economic-substance analysis. Some...transaction's business purpose, an economic-substance analysis examines...doctrine examines business purpose, economic substance or both. Phantom-corporati...

A Review of the Economic Substance Doctrine

Stanford Journal of Law, Business & Finance;  October 1, 2004 ;   Rector, Jeff;   787 words ......over form," "business purpose," and "economic substance" have been used...over form," "business purpose," and "economic substance" are found in...source of the economic substance doctrine, Gregory...

COLI program lacked economic substance.(corporate-owned life insurance)

The Tax Adviser;  January 1, 2000 ;   Morrissey, John;   787 words ......program lacked economic substance and business purpose (other than...independent business purpose) and lacked economic substance. In analyzing...consequences) and business purpose. For the economic substance of Winn-Dixie...

Times Mirror - a reflection of the past.

The Tax Adviser;  April 1, 2006 ;   White, Kelly Gruidi, Nick;   787 words ......application of the economic-substance, business-purpose and sham-transaction...Doctrines Although economic substance, business purpose and sham transaction...has no nontax business purpose and lacks economic substance in the form...

Mass. related-member interest or intangible expenses.

The Tax Adviser;  December 1, 2003 ;   Koppel, Michael D.;   787 words ......Sherwin-Williams proved economic substance and business purpose for its subsidiary...transactions. New Law Economic substance and business purpose are the keystones...or in full) or business purpose/economic substance. Part I: A Part...

Securing the annual gift tax exclusion for transfers of interests in...

The CPA Journal;  May 1, 2003 ;   Englebrecht, Ted; Anderson, Mary;   787 words ......determine its tax status: * Is there economic substance to the entity? This examination is...income tax purposes, an entity must have economic substance other than tax considerations. When determining the economic substance of the entity, two factors are considered in tandem. To ...

State developments in intangible property.

The Tax Adviser;  June 1, 2000 ;   Huizenga, David L.;   787 words ......MCI, in the business of providing...i.e., it had economic substance and was established...addressing the economic substance and business purpose issues, the...corporations with no economic substance. The comptroller...a legitimate business purpose. ...

Sherwin-Williams can deduct intercompany royalties and...

The Tax Adviser;  February 1, 2003 ;   Ochsenschlager, Thomas P.;   787 words ......to the conduct of its business ; see The Sherwin-Williams...transactions had no valid business purpose and (3) transactions were...transactions lacked any economic substance other than tax avoidance...transactions that have no economic substance or business...determined ...

Risk, return, and objective economic substance.

Virginia Tax Review;  March 22, 2008 ;   Luke, Charlene D.;   787 words ......I. INTRODUCTION 784 II. OBJECTIVE ECONOMIC SUBSTANCE 786 III. PRE-TAX PROFIT 793 A. Weighing...World 798 IV. Proposed Objective Economic Substance Inquiry 803 A. Comparables Test 804...CONCLUSION 831 I. Introduction The economic substance doctrine is a judicial method used...

Business-purpose and economic-substance tests. (Corporations &...

The Tax Adviser;  November 1, 2001 ;   Tapajna, Joseph J. Corrick, Stephen R. Ciesar, William W.;   787 words ......rcuit's standard for business purpose and economic substance. IES Industries...satisfied the business-purpose and economic-substance tests in a transaction...that it had no economic substance or business purpose other than the...

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

US Fed News Service, Including US State News;  June 1, 2007 ;     787 words ......substantial economic substance." The bill...substantial economic substance, and for other...Clarification of economic substance doctrine.Sec...transactions lacking economic substance, etc.Sec...transactions with no business purpose are not ...

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

Canadian Tax Journal;  January 1, 2006 ;   Jinyan Li*;   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...

NYC ruling upholds royalty deductions.(New York City)

The Tax Adviser;  June 1, 2004 ;   Amitay, Sharlene;   776 words ......attempt to inject a business-purpose /economic-substance requirement into...issue required a business-purpose and economic-substance finding as a condition...at that) the business-purpose/economic-substance avenue of attack...

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

Virginia Tax Review;  September 22, 2002 ;   Bird, Robert C. Tucker, Alan L.;   787 words ......transactions as lacking real economic substance and contended that Salina...did contain sufficient economic substance to be respected for taxation...governing tax shelters -- the economic substance doctrine. This part will...Part VI analyzes the economic substance of ...