'The End Result Test' Revisited, Part 1 - McDermott Will & Emery

‘The End Result Test’ Revisited, Part 1



In Depth

Philip Levine and Britt Haxton wrote this bylined article that traces the government’s ever-changing approach to the step transaction doctrine and considers future policy directions. The authors in particular examined how IRS and Treasury authorities have addressed step transaction in light of arguments that the use of the end result test in corporate stock transactions should be sharply curtailed, if not prohibited. Read the full article.