New Guidance For Examiners And Managers On The Application Of The Economic Substance Doctrine
Mondaq Business Briefing › United States Law Articles in English (2011)
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New Guidance For Examiners And Managers On The Application Of The Economic Substance Doctrine
The economic substance doctrine (ESD) was codified in March 2010 in the Health Care and Education Reconciliation Act of 2010 (HERA) as code section 7701(o), along with a new strict liability penalty of 20 percent, increased to 40 percent if adequate disclosure is not made on any underpayments attributable to transactions lacking economic substance or transactions that fail the requirements of any similar rule of law. The penalty is a strict liability penalty, not subject to any rea...
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