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Pepperdine University School of Law

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Monday, June 6, 2011

Columbia Journal of Tax Law Launches Tax Matters

Columbia The Columbia Journal of Tax Law has launched Tax Matters, a new feature with multiple short pieces responding to selected cutting-edge issues in tax law. Marvin A. Chirelstein (Columbia) wrote the inaugural prompt:

Codification of the Economic Substance Doctrine in 2010 – after years of controversy about whether codification was actually desirable – has generated a very substantial body of professional commentary, chiefly aimed at determining what the effect of the new provision is likely to be. Does the new Code section, § 7701(o), narrow the scope of traditional “tax planning” or do the planning maneuvers relied on in the past continue to be fully reliable? The question gains urgency from the addition of a penalty provision that is automatic in application and that tops out at 40% of understated income where the understatement is the consequence of an ESD infraction. Reactions by practitioners appear below.

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