Alston & Bird Tax Blog

Federal Tax ADVISORY: Fourth Circuit Economic Substance Doctrine

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The Tax Court takes on the Fourth Circuit’s version of the sham transaction doctrine. Our Federal Tax Group considers the implications going forward.

  • The Tax Court said no
  • The peculiar things about the opinion
  • The takeaway

Read the full advisory here.

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About Jasper L. (Jack) Cummings, Jr.

Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.

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