Substantial Economic Effect and Section 704(b) of the Internal Revenue Code episode artwork

EPISODE · Aug 18, 2026 · 23 MIN

Substantial Economic Effect and Section 704(b) of the Internal Revenue Code

from How Tax Works · host Falcon Rappaport & Berkman LLP

In episode 59 of How Tax Works, Matt Foreman discusses allocations and distributions, and the requirement that the allocations have Substantial Economic Effect, which is broken into two parts, (i) that the allocations have economic effect and (ii) that the economic effect is substantial on a pre-tax and post-tax basis.How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions. Follow us on Bluesky:@howtaxworks.bsky.socialThis podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged. This Podcast is Hosted by:Falcon Rappaport & Berkman LLP1185 Avenue of the Americas, Suite 1415New York, NY 10036(212) 203 [email protected]

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In episode 59 of How Tax Works, Matt Foreman discusses allocations and distributions, and the requirement that the allocations have Substantial Economic Effect, which is broken into two parts, (i) that the allocations have economic effect and (ii) that the economic effect is substantial on a pre-tax and post-tax basis. How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for...

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Substantial Economic Effect and Section 704(b) of the Internal Revenue Code

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