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By adopting agency theory, language conduit theory, and analogizing
evidence, language conduit theory shares the principles of agency theory
170) That language conduit theory was essentially similar to
Nazemian's holding--agency theory, language conduit theory, and
a hybrid of the agency theory and language conduit theory that predated
The doctrine can be applied by using the conduit theory, the step transaction doctrine or the economic substance doctrine.
The Service expanded the scope of the conduit theory in 1984 by disregarding (in two revenue rulings) the intermediary financial transactions of corporations located in a country with a reduced treaty withholding rate.
The IRS further expanded its application of the conduit theory in Letter Ruling (TAM) 9133004.