-
Step Transaction Doctrine Remains A Key Concern for Successful Planning
Step Transaction Doctrine Remains A Key Concern for Successful Planning
The Step-Transaction Doctrine is often employed by the IRS to challenge clients’ planning. There is limited time in2024, and soon the compressed planning period of 2025.
There are steps that practitioners might recommend to their clients to take now in preparation for future planning, which could potentially mitigate the possibility of the IRS successfully raising the step-transaction doctrine on audit. There is no universally accepted test to determine if the step-transaction doctrine should be applied to a particular transaction. However, Courts have relied on three concepts when evaluating whether the step-transaction doctrine should be applied: the mutual interdependence test, the end result test, and the binding commitment test.
