'The End Result Test' Revisited, Part 2 - McDermott Will & Emery

‘The End Result Test’ Revisited, Part 2


In Depth

Philip Levine and Britt Haxton wrote this bylined article, part two of their assessment on using the end result test in corporate stock transactions. “There probably never will be one answer for all situations in which the step transaction doctrine might apply, nor should there be,” the authors wrote, adding: “Different congressional policies underlie different [tax code] provisions … but not every formal difference should be sufficient to alter the tax result, and particular policies might require extra protection from overly artful tax planning.” Read the full article.