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

6 Pages Posted: 16 Jun 2003  

Samuel C. Thompson, Jr.

Pennsylvania State University, Penn State Law

Robert Allen Clary II

affiliation not provided to SSRN

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.

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

JEL Classification: H20, H25

Suggested Citation

Thompson, Jr., Samuel C. and Clary, Robert Allen, Coming in from the 'Cold': The Case for ESD Codification. Tax Notes, Vol. 99, No. 8, May 26, 2003. Available at SSRN: https://ssrn.com/abstract=415561 or http://dx.doi.org/10.2139/ssrn.415561

Samuel C. Thompson, Jr. (Contact Author)

Pennsylvania State University, Penn State Law ( email )

Lewis Katz Building
University Park, PA 16802
United States

Robert Allen Clary II

affiliation not provided to SSRN

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