Economic Substance

Alerts, Controlled Foreign Corporation (CFC), Economic Substance, GILTI, IRS Regulations, Subpart F

IRS Issues Proposed Regulations on Section 951(a)(2)(B) Planning

By Andrew Mirisis Dec 19, 2022
Administrative Procedure Act, Captive Insurance, Economic Substance, IRS Disclosure, IRS Notices

Micro-Captive Insurance Arrangements Disclosure

By Andrew Mirisis Nov 22, 2022
Economic Substance

Recent Tax Court Decision: Economic Substance and the Step Transaction Doctrine

By Matthew L. Roberts Feb 14, 2021
Economic Substance, Sham Trust, Trust

The Sham Trust Doctrine – When will a Court Disregard a Trust for Federal Tax Purposes?

By Jason B. Freeman Jul 21, 2019
Economic Substance

What is “Economic Substance?”

By Freeman Law Apr 09, 2018
Economic Substance, Substance over Form

Is “Form” “Substance” When it Comes to Law? The Future of the Doctrines of Economic Substance and Substance Over Form

By Jason B. Freeman Sep 15, 2017
Economic Substance

The Eleventh Circuit Weighs in on the United States Virgin Islands’ Economic Development Tax Credit

By Jason B. Freeman Sep 17, 2016