IRS Provides Guidance on Economic Substance Doctrine
On October 9, 2014, the IRS issued Notice 2014-58, which provides much needed guidance on the economic substance penalty under IRC §7701(o). The Notice speaks to 1) the definition of “transaction”, and 2) the application of the term “similar rule of law” for accuracy related penalties under IRC §6662(b)(6). It represents the IRS’ latest effort…