Options to Improve Tax Compliance and Reform Tax ExpendituresU.S. Government Printing Office, 2005 - 430 lappuses NOTE: NO FURTHER DISCOUNT FOR THIS PRINT PRODUCT--OVERSTOCK SALE -- Significantly reduced list price while supplies last |
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1.–5. rezultāts no 47.
... courts or potentially applying too broadly to many non - tax - shelter transactions . The proposal contained in this report addresses these concerns by requiring a higher level of judicial scrutiny only in the case of specific ...
... Courts generally deny claimed tax benefits if the transaction that gives rise to those benefits lacks economic substance independent of tax considerations -- notwithstanding that the purported activity actually occurred . The Tax Court ...
... courts have bifurcated a transaction in which independent activities with nontax objectives have been combined with an ... court must find that the taxpayer was motivated by no business purposes other than obtaining tax benefits in ...
... Court of Federal Claims questioned the continuing viability of the doctrine.46 The court also stated that " the use of the ' economic substance ' doctrine to trump ' mere compliance with the Code ' would violate the separation of powers ...
... court has concluded that financial accounting benefits arising from tax savings do not qualify as a non - tax business purpose . " However , based on court decisions that recognize the importance of financial accounting treatment ...