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On this edition, Robert Jennings and Elizabeth Sweigart discuss codification of the economic substance doctrine included in the Health Care and Education Reconciliation Act of 2010. Mr. Jennings and Ms. Sweigart analyze objective signposts introduced by the legislation to qualify transactional economic substance, and the impact of non-compliance penalties on corporate behavior. Copyright© 2010 LexisNexis, a division of Reed Elsevier Inc. All rights reserved.
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For commentary insights on this site, see Economic Substance and the Foreign Tax Credit Generator Regs.