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Tax Shelters or Efficient Tax Planning? A Theory of The Firm Perspective On the Economic Substance Doctrine

  • T. Christopher Borek
  • Angelo Frattarelli
  • Oliver Hart

Courts have articulated a number of legal tests to distinguish corporate transactions that have a legitimate business or economic purpose from those carried out largely, if not solely, for favorable tax treatment. We outline an approach to analyzing the economic substance of corporate transactions based on the property rights theory of the firm, and describe its application in two recent tax cases.

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File URL: http://www.nber.org/papers/w19081.pdf
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Paper provided by National Bureau of Economic Research, Inc in its series NBER Working Papers with number 19081.

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Date of creation: May 2013
Date of revision:
Handle: RePEc:nbr:nberwo:19081
Note: CF LE PE
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  1. Aghion, Philippe & Tirole, Jean, 1997. "Formal and Real Authority in Organizations," Scholarly Articles 4554125, Harvard University Department of Economics.
  2. Daron Acemoglu & Philippe Aghion & Rachel Griffith & Fabrizio Zilibotti, 2004. "Vertical Integration and Technology: Theory and Evidence," NBER Working Papers 10997, National Bureau of Economic Research, Inc.
  3. George P. Baker & Thomas N. Hubbard, 2004. "Contractibility and Asset Ownership: On-board Computers and Governance in U. S. Trucking," The Quarterly Journal of Economics, MIT Press, vol. 119(4), pages 1443-1479, November.
  4. Philippe Aghion & Richard Holden, 2011. "Incomplete Contracts and the Theory of the Firm: What Have We Learned over the Past 25 Years?," Journal of Economic Perspectives, American Economic Association, vol. 25(2), pages 181-97, Spring.
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