Economic Substance Changes Seen Most Affecting Firms in Three Circuits

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Taxpayers operating in the regions covered by the U.S. Courts of Appeal for the Second, Fourth, and Eighth Circuits will be most affected by the health care law's changes to the way the economic substance doctrine is applied to their tax transactions, says PricewaterhouseCoopers Managing Director for National Tax Services Corina Trainer. Under the new law, businesses and individuals will have to prove that their tax transactions have a business purpose other than reducing their tax liability. Trainer, speaking during a BNA Tax and Accounting webcast, says the new law and its stiff penalties for violations will still be felt beyond states in those circuits.