The Barnes Group Case, the Step Transaction Doctrine and Substance over Form

Journal
Carman, P.D.
United States
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2015 (Volume 17), No. 2
FormatPDF
EUR
40
| USD
45
(VAT excl.)

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.