Time: 3:00 PM-4:00 PM ET
Description: “Relevance” of the Economic Substance Doctrine after Liberty Global and Otay
This panel will examine the continuing “relevance” of the economic substance doctrine after Liberty Global and Otay, focusing on when section 7701(o) — or its common-law counterpart — should apply to a taxpayer’s transaction. Using these recent decisions as guideposts, the discussion will explore whether literal compliance with the Code is enough, or whether courts may look beyond form to test whether the transaction produced a tax benefit Congress did not intend.
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