Document Type
Article
Publication Date
1981
ISSN
0010-8847
Publisher
Cornell University, Cornell Law School
Language
en-US
Abstract
Pondering the human tendency to pay dearly for short-lived adornments, Shakespeare asks a question of interest to lawyers as well as poets: "Why so large cost, having so short a lease.. .? The lawyer's analysis of the issue might begin with a scenario set in an imaginary world in which the tax effects of business transactions are determined by their legal form rather than their economic substance. In such a world, each of two companies decides to build a new factory. One acquires the land outright, paying in several installments. The other enters into a shortterm lease at a very high rent with the option to purchase the land for a penny at the end of the lease term. Not surprisingly, the second company eventually exercises this option.
Recommended Citation
William W. Park,
Tax Characterization of International Leases: The Contours of Ownership
,
in
67
Cornell Law Review
103
(1981).
Available at:
https://scholarship.law.bu.edu/faculty_scholarship/1617
