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Expert Analysis

9th Circ. Adds Pressure To Reject Substance Over Form

By Lawrence Hill and Caitlin Tharp (August 2, 2021, 5:03 PM EDT) -- In Mazzei v. Commissioner of Internal Revenue, the U.S. Court of Appeals for the Ninth Circuit joined the U.S. Court of Appeals for the First Circuit, U.S. Court of Appeals for the Second Circuit and U.S. Court of Appeals for the Sixth Circuit in rejecting the substance-over-form doctrine for transactions involving a Roth IRA and a domestic international sales corporation or foreign service corporation, or FSC.[1]...

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