Economic Substance and TP
In this episode of Uncontrolled Opinions, we welcome Clark Armitage a leading international tax and transfer pricing lawyer to discuss about economic substance in the context of transfer pricing.
We dive into the economic substance doctrine —its origins, why it was codified in Section 7701(o), and how it intersects with modern transfer pricing, BEPS initiatives, and risk management. The conversation also covers current cases where the IRS has asserted the lack of economic substance in challenging taxpayers, litigation trends, and practical considerations for taxpayers structuring cross-border transactions.
We dive into the economic substance doctrine —its origins, why it was codified in Section 7701(o), and how it intersects with modern transfer pricing, BEPS initiatives, and risk management. The conversation also covers current cases where the IRS has asserted the lack of economic substance in challenging taxpayers, litigation trends, and practical considerations for taxpayers structuring cross-border transactions.
