NYSBA Issues Report No. 1228 on Codification of the Economic Substance Doctrine
I personally find most of the NYSBA reports to be very comprehensive and informative. This report does not differ in this respect. The report addresses the codification of economic substance, an issue that has been talked about in length, and rightfully so. I recently wrote a separate piece on Notice 2010-62, the first eagerly awaited Treasury guidance on the issue. As I mentioned in that note, economic substance has an universal tax implication that is not limited only to the tax exposure of private equity, venture capital and hedge fund. As to funds, the report highlights...
January 07, 2011 read more