United States - The Barnes Group Case, the Step Transaction Doctrine and Substance over Form
- United States
- P. Carman
- Derivatives & Financial Instruments, 2015 (Volume 17), No 2
- 27 March 2015
The author discusses the recent Barnes Group case, in which the taxpayers attempted to repatriate funds from Singapore by going through Bermuda. The IRS ignored two entities created as part of the transaction and treated the repatriated funds as a dividend from Singapore.