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Economic Substance Doctrine › Captive Insurance Company › Threshold Requirements

Latham & Watkins LLP

Tax Court to Consider Relevancy Threshold for Economic Substance Doctrine Under Section 7701(o)

Latham & Watkins LLP on

The Tax Court has invited amicus briefs and will address the codified meaning of the economic substance doctrine after increased IRS use of the doctrine to challenge taxpayer transactions. In a July 19, 2024, order in...more

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