Mike Tenenboym
Subscribe to Mike Tenenboym's PostsMike Tenenboym represents multinational organizations with respect to US federal income tax matters and international tax planning. His practice focuses on business taxation, particularly domestic and cross-border tax planning in connection with corporate restructurings, spin-offs, mergers, acquisitions and other major corporate transactions. Mike also handles tax policy matters, having drafted comment letters and articles with respect to the Tax Cuts and Jobs Act and CARES Act. Mike advises clients in a variety of industries, including aerospace, defense, semiconductor, pharmaceutical and telecommunications. Read Mike Tenenboym's full bio.
IRS Changes Position on Approval for Assertion of Codified Economic Substance Doctrine
By Mike Tenenboym on Apr 29, 2022
Posted In IRS Audits, IRS Guidance
In March 2010, Congress codified the economic substance doctrine in Internal Revenue Code (Code) Section 7701(o). The codification clarified that a conjunctive analysis applies in determining if the doctrine applies. The codified economic substance doctrine applies when a transaction does not have economic substance or lacks a business purpose. When the doctrine applies, a taxpayer is...
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