News & Analysis as of

Internal Revenue Service Economic Substance Doctrine Penalties

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Vinson & Elkins LLP

Planning for IRS Audits in an Era of Uncertainty

Vinson & Elkins LLP on

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

Holland & Hart LLP

Court News: Economic Substance Doctrine Nullifies Transaction

Holland & Hart LLP on

The IRS won a major economic substance case on October 31. A federal district court in Liberty Global, Inc. v. United States, No. 20-cv-03501 (D. Colo.), found that a planned corporate transaction lacked economic substance. ...more

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