Recently, the IRS issued a Large Business and International Directive, LB&I-4-0711-015, providing guidance for Examiners and Managers on the codified economic substance doctrine and related penalties. Excerpts from the Directive are included below.
Recently, the IRS issued a Large Business and International Directive, LB&I-4-0711-015, providing guidance for Examiners and Managers on the codified economic substance doctrine and related penalties. Excerpts from the Directive are included below.