NATIONAL BUREAU OF ECONOMIC RESEARCH
NATIONAL BUREAU OF ECONOMIC RESEARCH

Tax Shelters or Efficient Tax Planning? A Theory of The Firm Perspective On the Economic Substance Doctrine

T. Christopher Borek, Angelo Frattarelli, Oliver Hart

NBER Working Paper No. 19081
Issued in May 2013

---- Acknowledgements -----

Hart served as a testifying expert and Borek provided research support on behalf of the United States in WFC Holdings Corporation v. United States of America Civil Action No. 07-03320 (USDC D. Minn.) and Black & Decker Corp. v. United States Civill Action No. 02-2070 (USDC D. Md.) Frattarelli was lead trial counsel for the United States in Black & Decker. The views expressed are the authors’, and do not represent the official position of the Tax Division, the Department of Justice, any other Government agency, or the National Bureau of Economic Research. We thank Karen Burke, Gabriel Cappelli and Andrei Shleifer for useful discussion, and helpful comments. Hart gratefully acknowledges financial support from the U.S. National Science Foundation through the National Bureau of Economic Research.

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