Tag Archives: economic substance

Repealing Economic Substance Codification and Replacing It With What?

by Daniel Hemel — Monday, Feb. 20, 2017

The Republican effort to repeal the Affordable Care Act appears to be stalling. If and when it picks up again, the fate of section 7701(o) of the Internal Revenue Code will be far from the most consequential issue at stake. But section 7701(o), the provision added by the ACA that codifies the tax law economic […]