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Notice defines terms for economic substance doctrine

On Thursday, the IRS provided guidance defining “transaction” for purposes of applying the Sec. 7701(o) economic substance doctrine and “similar rule of law” for purposes of the Sec. 6662(b)(6) accuracy-related penalty (Notice 2014-58).
The economic substance doctrine is a common law judicial

    

Written by

Herman Yiu, CPA - Audit Taxation Advisory (212) 802-1428