Teleconference: Coltec and Its Consequences

Thursday, October 26, 2006, 2:00 p.m. - 3:30 p.m. EDT

Join IRS Chief Counsel Donald L. Korb and leading in-house and law firm tax counsel for a discussion of the Coltec decision and its potential consequences.

On July 12, 2006, the Federal Circuit reversed the Court of Federal Claims and issued its opinion in Coltec v. United States, 454 F.3d 1340 (2006). The court held that even though the taxpayer’s treatment of the transaction was technically correct under the Internal Revenue Code, the capital loss resulting from the transaction should be disallowed because the transaction lacked economic substance. The court’s interpretation and application of the economic substance doctrine is controversial and potentially could be applied to any transaction that comes under IRS scrutinty.

Speakers:
Donald L. Korb, Chief Counsel, Internal Revenue Service
Fred M. Greenwood III, Senior Tax Group Counsel, Ashland Inc.
Mark J. Silverman, Partner, Steptoe & Johnson LLP
Arthur L. Bailey, Partner, Steptoe & Johnson LLP

Questions may be submitted in advance, or during the teleconference via email to Jan Kinney at jkinney@steptoe.com. The teleconference is toll-free; there is no charge to participate.

For dial-in information and further details, please contact us at events@steptoe.com.