How to navigate economic substance guidance
On July 15 the Internal Revenue Service’s (IRS) Large Business & International (LB&I) division issued guidance to IRS examiners and examination case managers in the form of a directive concerning the application of the economic substance doctrine (ESD) that was recently codified in section 7701(o) of the Internal Revenue Code. Andrew Kim and William Skinner of Fenwick & West explain how taxpayers can navigate through the ESD, and also discuss recent US tax developments.
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