We use cookies on this site to enable your digital experience. By continuing to use this site, you are agreeing to our cookie policy. close


Tax Court Ruling Could Widen Divide Over Substance Doctrine

Law360 (March 23, 2018, 5:01 PM EDT) -- The U.S. Tax Court recently found that an arrangement that channeled money from a family business through a Bermuda-based foreign corporation to their Roth IRA ran afoul of the substance-over-form doctrine, threatening to crack open a divide over whether transactions that comply with the tax code can be invalidated under the doctrine.

In Mazzei v. Commissioner, decided March 5, the court applied a substance-over-form analysis and said the payments made from a Bermuda-based foreign sales corporation were, in substance, contributions from the Mazzei family members, and they...
To view the full article, register now.
Law360 Pro Say Podcast
Check out Law360's new podcast, Pro Say, which offers a weekly recap of both the biggest stories and hidden gems from the world of law.