Constructive Dividends and the Substance Over Form Doctrine

Posted on September 19, 2011 by lawhukukinet

Jack Townsend has an excellent post today (all of his posts are excellent) about C corporation constructive dividends. In United States v. Ellefsen, ___ F.3d ___, 2011 U.S. App. LEXIS 18684 (8th Cir. 2011), the appeals court addressed the issue of whether the IRS properly reclassified payments made by a C corporation to a trust, […]

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