Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more
The economic substance doctrine was historically a judicial doctrine. It was codified by the Health Care and Education Reconciliation Act of 2010 in Section7701(o). Although practitioners describe it as a codification,...more