The IRS won a major economic substance case on October 31. A federal district court in Liberty Global, Inc. v. United States, No. 20-cv-03501 (D. Colo.), found that a planned corporate transaction lacked economic substance. ...more
On April 11, 2023, the IRS issued proposed regulations concerning IRC ยง 6751(b). The statute requires that specific civil penalties must be personally approved (in writing) by the immediate supervisor of the individual making...more