Description
Understand the foundational principles of judicial doctrines relevant to taxation, including the economic substance doctrine, and its evolution over time.
As seen in cases such as Liberty Global and Perrigo, the IRS is more frequently asserting arguments based on the economic substance doctrine and related penalties. This webinar will outline the evolution of this doctrine, the history of the IRS position, and the current cases. This webinar will address this doctrine manifesting in audits, penalty considerations, and how practitioners should evaluate economic substance arguments at the outset of transactions.
Date: 2024-03-25 Start Time: 1:00 PM ET End Time: 2:40 PM ET
Learning Objectives
* You will be able to understand the foundational principles of judicial doctrines relevant to taxation, including the economic substance doctrine, and its evolution over time.
* You will be able to examine the historical development of the IRSs stance on the economic substance doctrine and its application in taxation cases.
* You will be able to analyze ongoing controversies surrounding the economic substance doctrine and related penalties.
* You will be able to explore audit practices about the economic substance doctrine and strict liability penalties, focusing on how these principles are applied in IRS audits.