CODIFYING THE ECONOMIC SUBSTANCE DOCTRINE: Giving an Agency an Enormous Power that Corrupts.
Tax avoidance, by its definition, is an oxymoron. Often times, there is an indicia of illegal overtone, albeit, legal. Tax avoidance is the reduction of tax liability by legal means. It often has pejorative overtones, where for example it is used to describe avoidance achieved by artificial arrangements of personal or business affairs to take advantage of loopholes, anomalies or other deficiencies of tax law.