Reconsidering Substance Over Form in PPL
Stanford Law School
December 10, 2012
Tax Notes, 2012
The controversy surrounding PPL v Commissioner has framed the issue as one of substance versus form, accepting that the tax in question is economically equivalent to a tax on income. However, the fact that the tax is levied on the basis of average profits rather than total profits causes it to differ from conventional income taxes in important ways.
Number of Pages in PDF File: 4
Date posted: December 24, 2012
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