Contact Paul +

Time limit is exhausted. Please reload CAPTCHA.

Substance over form

Substance-over-form doctrine applied to transfer of funds from foreign sub to domestic parent

Substance-over-form doctrine applied to transfer of funds from foreign sub to domestic parent

Chief Counsel Advice 201552027 In Chief Counsel Advice (CCA), IRS has concluded that a series of transfers of funds by multiple, related entities should not be respected for Federal income tax purposes. Background. Substance over form is a judicial doctrine in which a court looks to the objective economic realities of a transaction rather than to […]

Read the full article →
Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

Read More

Connect With Paul on Social Media

Practice Areas & Information

Certifications &
Associations
Member CA Bar Member Orange County Bar US Tax Court Attorney