Tax Law

Recent Posts

Tax Considerations for Taxpayers Applying the Economic Substance Doctrine
Posted on 5 Apr 2012 by Rufus v. Rhoades & Alexey Manasuev

The Background In 2010, Congress codified the economic substance doctrine, but left numerous unanswered questions for taxpayers on how to apply the doctrine. Along with codifying the economic substance doctrine, Congress also enacted strict liability... Read More

Tax Mitigation-Avoidance-Evasion
Posted on 5 Jun 2012 by Allison Christians

"Tax avoidance involves arrangement of a transaction in order to obtain a tax advantage, benefit, or reduction in a manner unintended by the tax law. It is an unacceptable manipulation of the law which is unlike legitimate tax mitigation. Mitigation... Read More

Apple Sidesteps Taxes – What’s Wrong With That?
Posted on 1 May 2012 by Christopher Bergin

A front-page article in Sunday's New York Times (" How Apple Sidesteps Billions in Taxes ") is getting quite the buzz. A couple of things about the article. While the Times piece recognizes that there is nothing illegal about the techniques... Read More

  • Blog Post: Tax Considerations for Taxpayers Applying the Economic Substance Doctrine

    The Background In 2010, Congress codified the economic substance doctrine, but left numerous unanswered questions for taxpayers on how to apply the doctrine. Along with codifying the economic substance doctrine, Congress also enacted strict liability penalties [ IRC § 6662(b)(6) (20 percent strict...
  • Blog Post: Apple Sidesteps Taxes – What’s Wrong With That?

    A front-page article in Sunday's New York Times (" How Apple Sidesteps Billions in Taxes ") is getting quite the buzz. A couple of things about the article. While the Times piece recognizes that there is nothing illegal about the techniques that Apple uses to minimize its taxes, it insinuates...
  • Blog Post: Tax Mitigation-Avoidance-Evasion

    "Tax avoidance involves arrangement of a transaction in order to obtain a tax advantage, benefit, or reduction in a manner unintended by the tax law. It is an unacceptable manipulation of the law which is unlike legitimate tax mitigation. Mitigation involves use of the tax law to achieve anticipated...