Andrew Weiner was quoted in a Law360 article published June 6, 2024 titled “Win May Embolden IRS Use Of Economic Substance Doctrine.” The article described how the common-law economic substance doctrine has evolved and how a recent Liberty Global lawsuit has highlighted controversy created in the interpretation of the doctrine.
From the article:
Andrew Weiner, who was an attorney in the U.S. Department of Justice’s Tax Division when the doctrine was codified, said the tax profession initially welcomes Section 7701 because it established “a level of consistency in its application for the benefit of taxpayers, practicioners and government attorneys.”
Although Section 7701 standardized the test, it created a new controversy over whether there are transactions that should not be subject to an inquiry under the doctrine, as Liberty Global argued in its suit against the government, said Weiner, who is now at Kostelanetz LLP.
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