Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
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
Economic substance regulations have been circulating in various forms across several jurisdictions during the last couple of years. They are being introduced across the globe in countries with low or no corporate taxation in...more