What troubles me is why there is any doubt in your mind as to what the purpose is.
Well, we passed a law in 2010 talking about economic substance saying that something has got to be real, it cannot be fake, and we are going...
They acknowledge it. But then when the IRS says they are going to allow that to be used, it undermines all the efforts we are making.
I am amazed at your reluctance to say yes to the most obvious question.
Will you check out that doctrine?
Thank God now there is a moratorium, but you put your stamp of approval on a mechanism which is inconsistent with what you are arguing in so...
They want to avoid triggering a tax? You do not think that is the whole purpose here, they want to avoid triggering a tax?
How do we give a green light to the use of them to qualify this kind of investment under our Tax Code?
Well, isn't the tax that is being avoided the corporate tax which would be triggered if it was not qualified income under Section 851?
Does the IRS care about people circumventing our tax laws through the use of shell/sham corporations offshore?
Now, why do you think mutual funds are setting up these corporations offshore rather than here in the United States?