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Penalties › Economic Substance Doctrine

Vinson & Elkins LLP

Planning for IRS Audits in an Era of Uncertainty

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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

Conyers

Ten Things You Need To Know About… BVI Economic Substance

Conyers on

The British Virgin Islands (the BVI), along with most other major offshore jurisdictions, has introduced “economic substance” requirements for entities carrying on certain specified activities. This economic substance regime...more

Conyers

Economic Substance Enforcement Regime Overview - Applicable to Insurance Entities

Conyers on

It has now been over a year since the updated Enforcement Guidelines: Economic Substance (the “Guidelines”) were issued on 31 March 2023, outlining the enforcement powers and processes of the Cayman Islands Tax Information...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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