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Reconsidering Substance Over Form in PPL

Jacob Goldin

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.

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Date posted: December 24, 2012  

Suggested Citation

Goldin, Jacob, Reconsidering Substance Over Form in PPL (December 10, 2012). Tax Notes, 2012. Available at SSRN: https://ssrn.com/abstract=2193390

Contact Information

Jacob Goldin (Contact Author)
Stanford Law School ( email )
559 Nathan Abbott Way
Stanford, CA 94305-8610
United States

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