Coming in from the 'Cold': The Case for ESD Codification

Abstract:     
This article builds on and elaborates on portions of an article the authors are currently publishing in the University of Southern California's annual publication, Major Tax Planning, entitled "Staying the Course: A Look at the Response to Corporate Inversions and Tax Shelters and the Need for More Direct Action." The article argues that Congress should codify the economic substance doctrine as proposed in Senate legislation.

Number of Pages in PDF File: 6

Keywords: Economic Substance Doctrine (ESD), ESD codification, tax shelter abuse

JEL Classification: H20, H25

Accepted Paper Series