• LB&I Internal Directive Limits Application of the Economic Substance Doctrine and Related Penalties, but Raises Concerns about Transparency and Consistency of Process
  • July 27, 2011
  • Law Firm: Sutherland Asbill Brennan LLP - Washington Office
  • On July 15, 2011, the IRS Large Business and International (LB&I) Division issued an internal directive that provides examiners and managers with guidelines for determining when it is appropriate to apply the codified economic substance doctrine (ESD) and related penalties (the Directive) (LB&I-4-0711-015).