TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

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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