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Expedited Challenges to Economic Substance: Erosion of Protections for Taxpayers and Problems for the IRS

September 2022

Related Practices

Hale Sheppard's article on "Expedited Challenges to Economic Substance: Erosion of Protections for Taxpayers and Problems for the IRS"

Hale E. Sheppard

Reports accompanying the codification of the economic substance doctrine, the official explanation by the Joint Committee on Taxation, several of the IRS Notices and memos covered in this article, and at least one major case all emphasize the inapplicability of the economic substance doctrine to situations involving congressional inducements to taxpayers, such as tax credits and deductions.

To learn more, read the full article here.