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Abstract: 

In any business transaction or other venture where tax planning is prominent, the parties involved must anticipate the possibility that the transaction will be recharacterized and treated differently from its actual structure, such that the desired tax benefits will not be realized. A transaction may be challenged through any one of several doctrines, including the business purpose doctrine, the substance over form doctrine, the sham transaction doctrine, and the economic substance doctrine.

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Affiliations:  1: Fried, Frank, Harris, Shriver & Jacobson; 2: Fried, Frank, Harris, Shriver & Jacobson.