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Corporate Taxes › Internal Revenue Service › Economic Substance Doctrine

Alston & Bird

Fourth Circuit Economic Substance Doctrine

Alston & Bird on

The Tax Court’s recent opinion in Austin v. Commissioner, TC Memo 2017-69, claims to be following the Fourth Circuit’s view of the economic substance doctrine by calling it the sham transaction doctrine, saying it is an issue...more

Skadden, Arps, Slate, Meagher & Flom LLP

"MassMutual Victory May Pave the Way for Earlier Deductions"

Skadden, Arps, Slate, Meagher & Flom LLP on

Earlier this month, Massachusetts Mutual Life Insurance Company (MassMutual), represented by Skadden, won a federal appeal permitting the company to deduct policyholder dividends in the year the dividends were declared, even...more

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