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Home / Opinion Digests / Surrender transactions can’t avoid tax liability (access required)

Surrender transactions can’t avoid tax liability (access required)

Where the taxpayers argued that they were not required to report $45.7 million of compensation income, the series of business transactions were devoid of economic substance and were thus insufficient for avoiding tax liability. Moreover, despite the taxpayers’ assertion they had a reasonable tax position, acted in good faith and the issues were novel, the ...