Hours
Mon - Fri : 9:00-5:00
Free Consultation

Tag

Substantial Economic Effect
What is economic effect in relation to substantial economic effect?  In previous articles I have discussed substantial economic effect in general and the background or history.  The regulations under IRC 704(b) test a partnership allocation to determine if it has substantial economic effect, and such is a two-part test.  First the allocation must have economic...
Read More
Under Internal Revenue Code Section 704, a partnership agreement is to determine a partner’s distributive share of the allocated tax items, such as income, loss, gain and credits.  This flexibility is, in part, what can make a partnership an attractive choice of entity for many small businesses or business owners.  However, it is also this...
Read More
Business owners may have heard about economic substance from their business attorneys or tax attorneys.  The Economic Substance Doctrine is a “test” by which the Internal Revenue Service will review certain transactions.  As a Denver tax attorney John McGuire has dealt with the Economic Substance Doctrine first hand for a number of clients and this...
Read More

Recent Comments