Taxation
The Ethereal Angel List
In March 2010, Congress codified the economic substance doctrine by adding section 7701(o) to the Code. Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152, § 1409, 124 Stat. 1029, 1067. To pass muster, a transaction now must meaningfully change the taxpayer’s economic position...