copy and paste this google map to your website or blog!
Press copy button and paste into your blog or website.
(Please switch to 'HTML' mode when posting into your blog. Examples: WordPress Example, Blogger Example)
Input Form:Deal with this potential dealer,buyer,seller,supplier,manufacturer,exporter,importer
(Any information to deal,buy, sell, quote for products or service)
26 U. S. Code § 7701 - Definitions - LII Legal Information Institute Notwithstanding any other provision of law, the Thrift Savings Fund is not subject to the nondiscrimination requirements applicable to arrangements described in section 401 (k) or to matching contributions (as described in section 401 (m)), so long as it meets the requirements of this section
Internal Revenue Code Section 7701(o) (o) Clarification of economic substance doctrine (1) Application of doctrine In the case of any transaction to which the economic substance doctrine is relevant, such transaction shall be treated as having economic substance only if--
§7701 (o), Clarification of Economic Substance Doctrine - CCH 7701 (o) (4) FinancialAccounting Benefits For purposes of paragraph (1) (B), achieving a financial accounting benefit shall not be taken into account as a purpose for entering into a transaction if the origin of such financial accounting benefit is a reduction of Federal income tax
U. S. Tax Court: Application of codified economic substance doctrine . . . In its first decision weighing application of the codified economic substance doctrine under section 7701(o) (enacted in 2010), the Tax Court held that under the clear statutory language of section 7701(o), the codified economic substance doctrine requires a threshold “relevancy” determination
Tax Court to Consider Relevancy Threshold for Economic Substance . . . Key Points: In 2010, Congress codified the economic substance doctrine in Section 7701(o)1 of the Internal Revenue Code, but to date there is minimal caselaw interpreting it because the IRS formerly required executive approval before an examining agent could invoke it
26 USC 7701: Definitions - uscode. house. gov Sections 1207 (f) and 1222 of Pub L 109–280, which directed the amendment of section 7701 without specifying the act to be amended, were executed to this section, which is section 7701 of the Internal Revenue Code of 1986, to reflect the probable intent of Congress
U. S. Tax Court Holds that § 7701 (o) Requires Threshold… | Fenwick Section 7701 (o) codifies a caselaw-based test, whereby a transaction is treated as having economic substance only if it satisfies both prongs Under the objective test, the transaction must meaningfully change the taxpayer’s economic position apart from federal income tax effects
The Economic Substance Doctrine According to Liberty Global and P For the Tax Court, Section 7701 (o) (5) (C) confirmed that Congress intended for courts to continue applying the traditional common law criteria for when the economic substance doctrine should be
RR-2024-14 - Internal Revenue Service 4 This revenue ruling does not address the application of § 7701(o) to transactions among unrelated partners Depending on the specific facts, § 7701(o) may apply to transactions among unrelated partners