The language conduit theory
is based on agency principles and should be applied on a case-by-case basis, the court said.
conduit[s]." (48) Under this language conduit theory, accurate
By adopting agency theory, language conduit theory, and analogizing
Nazemian also adopted the language conduit theory. (167) Language
conduit theory is a common law construction that allows a court to
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
The doctrine can be applied by using the conduit theory
, the step transaction doctrine or the economic substance doctrine.
30, 2003 passes through as ordinary income to the shareholder under traditional conduit theory
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.(45) A Canadian parent corporation purchased debentures from, and made a capital contribution to, its Dutch finance subsidiary.(46) On the same day, the Dutch finance subsidiary made loans in the same amounts to its U.S.