11/11/2009 01:00:00 PM EST
Robert Jennings and Elizabeth Taishoff Sweigart of Verse Consulting, LLC, on economic substance, transactional planning, documentation, tax benefits and best practices to optimize tax benefits
On this edition, Robert Jennings and Elizabeth Taishoff Sweigart discuss the Economic Substance Doctrine and corporate tax positions related to affiliate transactions. They examine these principles in the context of Schering-Plough v. U.S., and analyze essential elements of economic substance and non-tax business purpose, comparing IRS policy with the position of international tax authorities. Copyright© 2009 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.
For additional insights on this site, see Economic Substance and the Foreign Tax Credit Generator Regs.