The Fabulous New Substantial Contribution Test Is Made Even More Fabulous

 
Journal of International Taxation
December 2009

Douglas S. Stransky published an article in the December 2009 issue of the Journal of International Taxation, entitled "The Fabulous New Substantial Contribution Test Is Made Even More Fabulous." In this article, the authors discuss the Final Treasury Regulations that make significant taxpayer-friendly revisions and clarifications to the general operation of the substantial contribution test and the indicia of manufacturing.