Codification of Economic Substance Tops IRS Guidance Wish List

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One of the main issues tax practitioners are hoping for more guidance with in the 2011-2012 Treasury Department-IRS priority guidance list is the codification of economic substance, Michael Desmond, partner with Bingham McCutchen, tells BNA. “That's probably on top of everyone's list on what should come out, although the IRS has been fairly clear that it doesn't plan to issue any,” Desmond says. The IRS, in Notice 2011-39, made its annual request for recommendations on issues that tax practitioners want to see guidance on in the coming plan year, which runs from July 1, 2011, through June 30, 2012.