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Technical Explanation of H.R. 5095 (the "American Competitiveness Act of 2002")

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Technical Explanation of H.R. 5095 (the "American Competitiveness Act of 2002")

by United States Congress Joint

About this title: OCLC Number: 55150547 Excerpt: ...11 denied tax benefits on the grounds that the subject transactions lacked profit potential. In addition, some courts have applied the economic substance doctrine to disallow tax benefits in transactions in which a taxpayer was exposed to risk and the transaction had a profit potential, but the court concluded that the economic risks and profit potential were insignificant when 12 compared to the tax benefits. Under this analysis, the taxpayer's profit potential must be more than nominal. ... read more

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