Taxpayers may sometimes find themselves in the crosshairs of the US Internal Revenue Service even where a transaction technically complies with the Internal Revenue Code but serves no real purpose apart from its tax effects. Courts have developed tools to invalidate transactions that are contrary to the spirit of the Internal Revenue Code, one of which is the ‘economic substance’ doctrine. The doctrine has since been distilled into a two-pronged test under Section 7701(o) of the code, where determination of both prongs often involves a complex multi-factor analysis.
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Benjamin Alarie is CEO of Blue J Legal and a full professor at the University of Toronto, where he holds the Osler Chair in Business Law. He researches and teaches in taxation law and judicial decision making, and was awarded the Alan Mewett QC Prize for excellence in teaching by the law school’s 2009 graduating class. Before becoming a full-time professor in 2004, he completed graduate work at the Yale Law School and was a law clerk for Madam Justice Louise Arbour at the Supreme Court of Canada. He has dozens of academic publications to his name and his research has been funded by the Social Sciences and Humanities Research Council, the Canadian Foundation for Innovation and the Ontario Ministry of Research and Innovation. He has co-authored several editions of a leading legal text on tax law, Canadian Income Tax Law, including the most recent sixth edition (LexisNexis, 2018).