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New BNA Tax Portfolio Analyzes Economic Substance Doctrine

NEWS RELEASE

Contacts:
Mark Carrington
(202) 530-1728

Washington, DC (March 8, 2007) – BNA®, publisher of the authoritative and universally recognized Tax Management Portfolios, has released the latest addition to the U.S. Income series. Portfolio 508, Economic Substance Doctrine analyses the economic substance doctrine and associated judicial anti-abuse doctrines. The Economic Substance Doctrine is designed to prevent favorable tax results from transactions that literally satisfy one or more sections of the Internal Revenue Code but nevertheless appear "too good to be true." Although often separately identified, these interrelated doctrines must be considered together rather than in isolation.

Prepared by Yoram Keinan, this Portfolio first analyzes landmark court decisions that have established the various judicial anti-abuse doctrines. The Portfolio then focuses on the economic substance doctrine. It dissects the doctrine and explains the critical "profit" requirement. Subsequent sections address associated issues including economic substance of an entity and integration or bifurcation of a series of transactions.

In recent years, legislation has been proposed in various iterations to codify the economic substance doctrine. The Portfolio describes and compares these proposals. Finally, the Portfolio examines in detail recent cases focusing on economic substance.

A Senior Manager with Ernst & Young's National Tax Department in Washington, D.C., Mr. Keinan specializes in United States taxation of financial products and institutions and represents major investment banks and financial institutions in the United States. Prior to joining Ernst & Young's National Tax Department, Mr. Keinan practiced with Shearman & Sterling and with Ernst & Young's tax department in Israel. Mr. Keinan has authored numerous articles and has taught in Harvard's International Tax Program, Kennedy School of Government, and School of Arts and Sciences (Department of Economics). Mr. Keinan’s degrees include: B.A., LL.B., Tel Aviv University; LL.M. (Taxation), Hebrew University; M.B.A., Bar Ilan University; M.P.A., LL.M. (International Taxation), Harvard University; LL.M. (Taxation), S.J.D., University of Michigan. In addition to practicing with Ernst & Young, Mr. Keinan serves as an adjunct professor in the Graduate Tax (LL.M.) Program at Georgetown University Law Center.

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