Taxpayers may sometimes find themselves in the crosshairs of the US Internal Revenue Service even where a transaction technically complies with the Internal Revenue Code but serves no real purpose apart from its tax effects. Courts have developed tools to invalidate transactions that are contrary to the spirit of the Internal Revenue Code, one of which is the ‘economic substance’ doctrine. The doctrine has since been distilled into a two-pronged test under Section 7701(o) of the code, where determination of both prongs often involves a complex multi-factor analysis.
This webinar will cover:
- The current state of the law in determining whether a transaction has economic substance
- Notable economic substance cases from recent years
- Advancements in dynamic algorithms that can predict the outcome of challenging economic substance cases
- How machine learning and data are used to identify the variables that will most influence the way courts are likely to rule