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The ITPF News Blog is managed by the students at the University of Florida Levin College of Law International Tax LLM Program.

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Recent Articles


Stock Lending Notices, Unwritten Intent, and Economic Substance

Mike Gaffney calls for the withdrawal of a 2012 generic legal advice memorandum that he believes inappropriately applies the economic substance doctrine in the tax ownership area of fungible securities.

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By Gaffney, Mike, posted on Monday January 5, 2015

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