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Federal Tax ADVISORY: Fourth Circuit Economic Substance Doctrine

May 1, 2017 By Jasper L. (Jack) Cummings, Jr.

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. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Austin, Austin v. Commissioner, Bank of NY Mellon Corp. v. Commissioner, Fourth Circuit, Section 7701, Section 7701(o), Section 83, Tax Court, TC Memo 2017-69, Toyota World Inc. v. Commissioner

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