Sentences with phrase «economic substance»

What's more, there are legal doctrines the IRS might use to attack the result, including the recently codified economic substance doctrine.

This «recovery» is mostly artificial as it is based largely on these bubbles (I call it a «bubblecovery «-RRB- and very little on true economic substance.

«In the long run, management stressing accounting appearance over economic substance usually achieve little of either» Warren Buffett

Mr. Murphy's substantive experience includes a wide range of complex tax issues, including economic substance and business purpose, foreign tax credits, debt / equity, transfer pricing and a variety...

A transaction has economic substance if: (1) the transaction changes in a meaningful way (apart from Federal income tax effects) the taxpayer's economic position; and (2) the taxpayer has a substantial purpose (apart from Federal income tax effects) for entering into such transaction.

These kinds of the transaction go against Economic Substance Doctrine.

You might find yourself creating a situation that looks okay on paper but gets overturned in an audit because it lacked economic substance (substance over form).

At the same time, the Treasury should work with Congress to prevent transfer pricing abuses and to limit tax shelters that do not have economic substance.

I also told him that I didn't think the transaction was ethical, because restructuring merely to avoid tax, and change the GAAP statement impact had no economic substance.

From cases addressing the scope of the economic substance doctrine, to constitutional protections against retroactive taxation, to access to a federal forum to challenge state tax laws, the Litigation Center is working to promote a less burdensome, more predictable, and fairer tax system.

It consists of 15 action plans where the aim is to curtail rampant tax avoidance strategies and to close gaps that have allowed multinational entities (MNEs) to exploit loopholes and mismatches in tax rules to artificially reduce their tax base, and shift profits to low or no - tax locations where the MNEs have little or no economic substance.

In addition, the IRS can challenge a settlement in which the allocation of punitive to compensatory damages does not accurately reflect the «economic substance» of the settlement.

Furthermore, the IRS has the legal authority to challenge the way a settlement is structured in cases where the ratio of punitive to compensatory damages does not reflect the «economic substance» of the settlement.

We structure our business to ensure that commercial and economic substance is first and foremost, with full regard to the potential impact on our reputation.

Providing assistance and testimony in tax litigation cases relating to economic effects, economic substance, risk management, transfer pricing and valuation