IRS Issues Field Directive on Economic SubstanceBryon A. Christensen,Armando Gomez,Julia M. Kazaks,Pamela F. Olson,Cary D. Pugh, July 21, 2011
On July 15, 2011, the Internal Revenue Service (the Service) released a directive providing guidance for Service examiners and managers on the application of the codified economic substance doctrine and related penalties (the Directive). Although issued in the form of internal field instructions...