Committee on Taxation.Committee on Taxation (COT) Staff Liaison: Mark Prysock COT will file comments on a Senate legislative proposal to codify codify to arrange and label a system of laws. the judicially created "economic substance" doctrine. The proposal will likely provide that a transaction has economic substance (and thus satisfies the economic substance doctrine) only if the taxpayer establishes that: 1) the transaction changes in a meaningful way (apart from federal, foreign, state and/or and/or conj. Used to indicate that either or both of the items connected by it are involved. Usage Note: And/or is widely used in legal and business writing. local income tax consequences) the taxpayer's economic position; 2) the taxpayer has a substantial non-tax purpose for entering into such transaction; and 3) the transaction is a reasonable means of accomplishing such purpose. COT has actively opposed op·pose v. op·posed, op·pos·ing, op·pos·es v.tr. 1. To be in contention or conflict with: oppose the enemy force. 2. recent Congressional attempts to codify the doctrine, successfully arguing that the proposed legislative language is extremely broad and could result in the denial denial, in psychology, an ego defense mechanism that operates unconsciously to resolve emotional conflict, and to allay anxiety by refusing to perceive the more unpleasant aspects of external reality. of tax benefits for legitimate business transactions. |
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