Codification of the economic substance doctrine: bright lines may create new uncertainties for tax-sensitive transactions *

USA - March 24 2010
The common law "economic substance doctrine" would be codified as a mandatory two-prong test should the reconciliation bill to the new health care legislation be enacted.

Co-authors: Dana P. Newman, James T. Chudy, Thomas D. Morton, Julie A. Divola.

President signs HIRE Act, including FACTA provisions combating offshore tax evasion *

USA - March 18 2010
On March 18, 2010, President Obama signed the Hiring Incentives to Restore Employment Act (the "Act"), which hopes to create jobs with measures such as a "Social Security holiday" for employers that hire previously unemployed workers, an extension of highway and mass transit funding, and an expansion of the Build America Bonds program.

Co-authors: James T. Chudy, Harsha Reddy.