Understand the foundational principles of judicial doctrines relevant to taxation, including the economic substance doctrine, and its evolution over time.
As seen in cases such as Liberty Global and Perrigo, the IRS is more frequently asserting arguments based on the economic substance doctrine and related penalties. This webinar will outline the evolution of this doctrine, the history of the IRS’ position, and the current cases. This webinar will address this doctrine manifesting in audits, penalty considerations, and how practitioners should evaluate economic substance arguments at the outset of transactions.
Learning Objectives
- You will be able to understand the foundational principles of judicial doctrines relevant to taxation, including the economic substance doctrine, and its evolution over time.
- You will be able to examine the historical development of the IRS’s stance on the economic substance doctrine and its application in taxation cases.
- You will be able to analyze ongoing controversies surrounding the economic substance doctrine and related penalties.
- You will be able to explore audit practices about the economic substance doctrine and strict liability penalties, focusing on how these principles are applied in IRS audits.
Agenda
Overview
- Background on Judicial Principles
- History of IRS Position
- Ongoing Controversies
Practical Considerations
- Audit Practices and Strict Liability Penalties
- Planning Considerations
Speakers
Mr Samuel Lapin,
Senior associate in the Tax Department ,
Miller & Chevalier Chartered- Senior associate in the Tax Department at Miller & Chevalier Chartered
- Practice concentrates on tax controversy matters, including administrative appeals and tax litigation
- Conducts regular seminars and workshops on administrative practice and procedure and tax controversy issues
- Chair of the New Tax Practitioners Committee, Taxation Community, District of Columbia Bar
Clerk, The Honorable Cary Douglas Pugh, United States Tax Court
- J.D. degree, cum laude, Temple University Beasley School of Law; B.A. degree, University of Pittsburgh
- Can be contacted at 202-626-5807 or slapin@milchev.com
Caroline Reaves,
Miller & Chevalier Chartered- Counsel at Miller & Chevalier Chartered
- Practice covers a broad range of federal income tax matters with a focus on cross-border transactional issues and business activities
- Represents domestic and international corporations, partnerships, individuals, and S corporations in the energy, technology, consumer product, healthcare, and industrial sectors
- Named “One to Watch” in Litigation & Controversy and Tax Law by The Best Lawyers in America, 2024
- Frequent speaker at American Bar Association (ABA), International Fiscal Association, Federal Bar Association, and Tax Executives Institute (TEI) events and presents on a broad range of topics, including transfer pricing, Pillar 1 and Pillar 2, and common-law doctrines
- J.D. degree, with honors, The George Washington University; B.A. degree, Colby College
Who Should Attend
This live webinar is designed for accountants, CPAs, controllers, attorneys, presidents, vice presidents, CFOs, tax managers, tax preparers, finance directors, bookkeepers and enrolled agents.
