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.
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For additional insights on this site, see Economic Substance and the Foreign Tax Credit Generator Regs.