Codification of Economic Substance


The CLE Conference Center
Wanamaker Bldg., 10th Floor, Ste. 1010, Philadelphia, PA

Date & Time

Start Date: 04/26/2011


The Health Care and Education Reconciliation Act of 2010 codified the existing economic substance doctrine. The new legislation imposes a strict liability penalty for failing to satisfy the economic substance test, which will likely result in more aggressive use of the doctrine by the IRS in corporate audits. The IRS has indicated that it will not release any list of safe harbor transactions. Join our expert panel as they guide you through the new provisions codifying the economic substance doctrine and analyzing the impact of these new rules on tax planning and tax controversy disputes.


Thomas J. Gallagher



Thomas J. Gallagher


(215) 665-4656