Tax Shelters or Efficient Tax Planning? A Theory of The Firm Perspective On the Economic Substance Doctrine

Courts have articulated a number of legal tests to distinguish corporate transactions that have a legitimate business or economic purpose from those carried out largely, if not solely, for favorable tax treatment. We outline an approach to analyzing the economic substance of corporate transactions based on the property rights theory of the firm, and describe its application in two recent tax cases.

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Year of publication:	2013-05
Authors:	Hart, Oliver D. ; Borek, T. Christopher ; Frattarelli, Angelo
Institutions:	National Bureau of Economic Research (NBER)

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Extent:	application/pdf
Series:	NBER Working Papers.
Type of publication:	Book / Working Paper
Notes:	CF LE PE The price is Paper copy available by mail Number 19081
Classification:	C24 - Truncated and Censored Models ; D02 - Institutions: Design, Formation, and Operations ; D23 - Organizational Behavior; Transaction Costs; Property Rights ; G34 - Mergers; Acquisitions; Restructuring; Corporate Governance ; H25 - Business Taxes and Subsidies ; K34 - Tax Law
Source:	RePEc - Research Papers in Economics

Persistent link: https://www.econbiz.de/10010821949