Subscribe to the Tax Headline RSS feed | Subscribe to the Tax Headline feed via EmailNewly Codified Economic Substance Doctrine Could Mean More IRS Challenges, Practitioners Say
May 26, 2010 in Daily Tax Report · Leave a Comment
The newly codified economic substance doctrine may clear the way for Internal Revenue Service challenges to a broader range of transactions than before, tax practitioners said May 20.
The statutory change may signal that “IRS is going to start to attack other areas beyond traditional shelters,” Sam Kaywood, Alston & Bird LLP, Atlanta, said.
Kaywood, who moderated a panel on the issue at the Atlanta Region International Fiscal Association, said that in the international area, the government could use the codified doctrine to address transfer pricing transactions and deals involving deferral and the foreign tax credit, among others.
