The taxpayers’ deductions from microcaptive insurance transactions lacked economic substance under Sec. 7701(o), the Tax ...
The IRS won a major economic substance case on October 31. A federal district court in Liberty Global, Inc. v. United States, No. 20-cv-03501 (D. Colo.), found that a planned corporate transaction ...
Editor’s Note: The Hart Scott Rodino Act (HSR Act), a pivotal federal law, mandates companies to notify the Federal Trade Commission (FTC) and the Department of Justice (DOJ) before finalizing mergers ...
In this paper, the author introduces the theory and method of transaction cost economics to identify the essence of e-commerce model by explicating its core objective and function. From the ...
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