Courts have articulated a number of legal tests to distinguish corporate transactions that have a legitimate business or economic purpose from those carried out largely, if not solely, for favorable tax treatment. We outline an approach to analyzing the economic substance of corporate transactions based on the property rights theory of the firm and describe its application in two recent tax cases.Economic
Transactions designed to avoid statutory provisions bear the legal risk that courts deem them unsucc...
Notwithstanding its political dimension, international tax avoidance is also the result of a regulat...
This article presents a critique of the economic substance doctrine and suggests an alternative. The...
Courts have articulated a number of legal tests to distinguish corporate transactions that have a le...
The economic substance doctrine is used by the IRS and courts to distinguish legal tax avoidance fro...
Cappelli and Andrei Shleifer for useful discussion, and helpful comments. Hart gratefully acknowledg...
An important challenge of the modern tax law is efficient countering of tax avoidance. One of the wa...
The foreign tax credit, which saves U.S. taxpayers from paying both foreign and domestic income taxe...
As the tax agency had aggressively examined and determined the suspected tax avoidance schemes, seve...
Almost every federal circuit, as well as Congress, has weighed in on the economic substance doctrine...
Most previous legislative attacks on corporate tax shelters have targeted specific transactions and ...
Some aspects of business value management are considered. Important attention is paid to the managem...
The economic substance doctrine has no basis in economics. The fact that a transaction has an after-...
In interpreting tax regulations, economic interpretation has the importance of the role or principle...
Concerning taxation on corporations, the fundamental problem is how we take the concept of corporate...
Transactions designed to avoid statutory provisions bear the legal risk that courts deem them unsucc...
Notwithstanding its political dimension, international tax avoidance is also the result of a regulat...
This article presents a critique of the economic substance doctrine and suggests an alternative. The...
Courts have articulated a number of legal tests to distinguish corporate transactions that have a le...
The economic substance doctrine is used by the IRS and courts to distinguish legal tax avoidance fro...
Cappelli and Andrei Shleifer for useful discussion, and helpful comments. Hart gratefully acknowledg...
An important challenge of the modern tax law is efficient countering of tax avoidance. One of the wa...
The foreign tax credit, which saves U.S. taxpayers from paying both foreign and domestic income taxe...
As the tax agency had aggressively examined and determined the suspected tax avoidance schemes, seve...
Almost every federal circuit, as well as Congress, has weighed in on the economic substance doctrine...
Most previous legislative attacks on corporate tax shelters have targeted specific transactions and ...
Some aspects of business value management are considered. Important attention is paid to the managem...
The economic substance doctrine has no basis in economics. The fact that a transaction has an after-...
In interpreting tax regulations, economic interpretation has the importance of the role or principle...
Concerning taxation on corporations, the fundamental problem is how we take the concept of corporate...
Transactions designed to avoid statutory provisions bear the legal risk that courts deem them unsucc...
Notwithstanding its political dimension, international tax avoidance is also the result of a regulat...
This article presents a critique of the economic substance doctrine and suggests an alternative. The...