Codification may be in future for economic substance doctrine. (cover story)

The article report renewed attention gained by the economic substance doctrine by recent court decisions in the U.S. as of March 2008. It is anticipated that the doctrine would become codified in the future despite the failure of legislative proposals to codify the doctrine over the past decade because of its possibility as a pay for or revenue raiser. The doctrine allows courts to deny claimed tax benefits of a transaction if the transaction lacks economic substance.