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What’S In A Name? The Role Of Danielson In The Taxation Of Credit Card Securitizations, Grace S. Lee
What’S In A Name? The Role Of Danielson In The Taxation Of Credit Card Securitizations, Grace S. Lee
Grace S Lee
While the doctrine of substance over form has been a part of tax law for over seventy years, courts look disfavorably upon taxpayers who invoke the doctrine to argue against the forms of their own transactions under what is commonly referred to as the Danielson rule. Although the Danielson rule appears sound on its face, it holds less force when applied outside of its original context. In particular, the Danielson rule should not apply when the form given to a transaction is given for non-tax reasons, such as to achieve a particular accounting treatment. The taxation of credit card securitizations …
What’S In A Name? The Role Of Danielson In The Taxation Of Credit Card Securitizations, Grace S. Lee
What’S In A Name? The Role Of Danielson In The Taxation Of Credit Card Securitizations, Grace S. Lee
Grace S Lee
While the doctrine of substance over form has been a part of tax law for over seventy years, courts look disfavorably upon taxpayers who invoke the doctrine to argue against the forms of their own transactions under what is commonly referred to as the Danielson rule. Although the Danielson rule appears sound on its face, it holds less force when applied outside of its original context. In particular, the Danielson rule should not apply when the form given to a transaction is given for non-tax reasons, such as to achieve a particular accounting treatment. The taxation of credit card securitizations …