Codification of Economic Substance Affects All Tax Practitioners
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Fowler, Gregory M.
Mattson, Andrew M.
Bresnahan, James F
The article discusses the uncertainty surrounding the codification of the economic substance doctrine and its impact on the professional practice and obligations of certified public accountants (CPAs) in the U.S. in August 2011. It says that the doctrine's codification affects the Circular 230 obligations of practitioners, which urge the establishment of best practices when performing before the Internal Revenue Service (IRS). The terms of the economic substance doctrine are also discussed.
Gregory M. Fowler, Andrew M. Mattson, James F. Bresnahan II, Codification of Economic Substance Affects All Tax Practitioners, 42 Tax Adviser 540 (2011) (Thomas J. Purcell III, ed.).