The Barnes Group Case, the Step Transaction Doctrine and Substance over Form
Journal
United States
Finance and Capital Markets (formerly Derivatives & Financial Instruments) 2015 (Volume 17), No. 2
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.