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.
Agenda
Faculty
Samuel Lapin
Miller & Chevalier Chartered
- Counsel in the Tax Department at Miller & Chevalier Chartered
- Practice concentrates on tax controversy and litigation matters
- Experience in representing clients during IRS audits and before the IRS Independent Office of Appeals on a variety of issues, including the R&D credit, partnership basis adjustments, management fee waivers, charitable contributions, and collection and penalty issues
- Assists clients with international tax planning and tax policy matters
- Active member of the ABA Tax Section and the DC Bar Tax Community and former Law Clerk to Judge Cary Douglas Pugh on the U.S. Tax Court
- Recognized by The Best Lawyers in America for Litigation and Controversy - Tax (Ones to Watch) and Tax Law (Ones to Watch)
- Conducts regular seminars and workshops on administrative practice and procedure and tax controversy issues
- 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 [email protected]
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
- Can be contacted at 202-626-5939 or [email protected]
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