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Form, Substance and Directionality in Subchapter C

In teaching law students and young tax associates, I often point out that there are two fundamental principles in Subchapter C of the Code: "Substance controls, form does not" and "form controls, substance does not." This intentionally paradoxical formulation is intended to convey one of the great challenges of practicing in the corporate tax area...

Lewis R. Steinberg

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