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Description
In July, the Commissioner for the Large Business & International Division issued a Directive entitled "Guidance for Examiners and Managers on the Codification of Economic Substance Doctrine and Related Penalties." The Directive does not answer substantive questions regarding the codified economic substance doctrine under section 7701(o). But it does provide important insights into how the IRS might apply the doctrine on audit, including a description of a four step process for examiners and managers to follow to evaluate whether to raise the doctrine and related strict liability penalty. The speakers will provide an overview of the Directive and discuss how it may impact an LB&I examination.
This audio CD-ROM includes full program audio and course materials.
System Requirements for CD-ROM
The CD-ROM for this title includes an audio or video file and the course materials and CLE certificates in PDF. This CD-ROM requires a PC or Mac with a CD-ROM drive. The disc will not play in a standard audio CD player, but CD-ROMs containing MP3 audio can be played in many MP3 compatible CD players. To play MP3 audio on your computer, you will need a media player such as iTunes,Windows Media Player, RealPlayer, or Quicktime. Some CD-ROMs include video files in WMV format, which require Windows Media Player or a media player capable of playing files in Windows Media format.
Course materials and CLE certificates require Adobe Reader® or software capable of opening PDF files .
