July 8, 2011
Jackel: When Is the Economic Substance Doctrine Relevant?Monte A. Jackel (PricewaterhouseCoopers, Washington, D.C.) has published When Is the Economic Substance Doctrine Relevant?, 132 Tax Notes 77 (July 5, 2011):
Jackel reviews the recent Third Circuit Schering-Plough decision and attempts to determine whether the court’s express refusal to address the lower court’s economic substance analysis provides any guidance for future cases under new § 7701(o).
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