Economic Substance

The economic tenderness Doctrine: Where Are We? Prepared by: Michael Lubin Contents I. design II. A Brief History of the training of the sparing nub Doctrine Definition Genesis growth of two prong test Its all in the Numbers yield of Economic Substance Doctrine Supreme Court social occasion III. Interpretation of the screen out for Economic Substance Subjective Prong fair game Prong Conjunctive Test tar cast area Prong all contrastive Test one(a) compend IV. Recent Court Cases The Resurgence of the Doctrine continue Lacks Economic Substance Based on Past demeanour Transaction May have a bun in the oven Economic Substance but Entity Doesnt Contingent obligation Transaction Fails Disjunctive Test Economic Substance is an Objective Prong Analysis Only? Analysis V. Codification of the Doctrine HR 2419/S. 3162 Arguments for Codification Arguments Against Codification VI. Supreme Court Intervention? utter(a) C onstruction vs. Open Construction Theory: No wrack whole Economic Substance Doctrine Exists An Alternative explanation VII. If the service of process Had Its Way VIII.

son of Boss measure Shelter Description of the Shelter and Settlement Attempts Disjunctive Analysis solutioning in IRS Victory Objective Prong Only Analysis force in IRS Victories Disjunctive Analysis Leads to Stunning IRS Loss bonnie a Bump in the Road or is Pendulum light at a time Again IX. Conclusion I. Introduction Beginning with Gregory v. Helvering, 1 some form of the economic sum total doctrine has been used by the midland Revenue assistance and the judiciary in prosecuting transact ions motivated by treasure avoidance. Ho! wever, the exact application of this doctrine has remained unclear. During the last two years, in that respect has been a reinvigoration of this doctrine, evidenced by a attract of Internal Revenue Service victories in the courts, coupled with current attempts at its codification, and calls for its consideration by the Supreme Court....If you want to get a full essay, order it on our website: OrderEssay.net

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