Codification Economic Substance Doctrine

[solomon]

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=111_cong_bills&docid=f:h4872enr.txt.pdf

Title I
Subtitle E
Section 1409
Starts on Page 39

[Black Bart]

Say Sol,

What's the short version? What are they saying?

[solomon]

What's the short version? What are they saying?

Well, the "doctrine" has been around for a lengthy time. The short version for the government is that it expects to raise at least five billion dollars over ten years from the imposition of the penalties.

Under §6662, it is 20% and if non-disclosed transactions it is then 40%.

[solomon]

What's the short version? What are they saying?

Here you go Bart - IRS finally issued a Notice.

http://www.irs.gov/pub/irs-drop/n-10-62.pdf