In a decision released shortly after the Tax Court's decision in the Countryside case, the Seventh Circuit in Valero upheld the district court's order, rejecting Valero's claim that the tax shelter
exception to the tax practitioner/client privilege did not apply to the documents in question.
Can you think of an example where the tax shelter
initiative offer is different from how Appeals might settle the case through the exercise of its traditional authority or Fast Track Settlement means?
At the time, the IRS was investigating more than 100 tax shelter
promoters, including accounting firms, law firms, and financial institutions.
Individuals and corporations that participated in a tax shelter
must disclose by submitting a copy of the federal Form 8886, Reportable Transaction Disclosure Statement to Minnesota.
In addition, the Senate bill includes provisions addressing Enron-related tax shelter
One good example of looking at the quality of the investment rather than the tax savings is to look at the most commonly used tax shelter
-- the RRSP.
Nevertheless, the Treasury Department maintains that more aggressive enforcement by the IRS alone is not sufficient to halt tax shelter
abuses, and additional enforcement laws must be passed by Congress.
Those taxpayers who do not sign up to participate in California's program will be assessed full penalties on the tax shelter
The final instructions indicate that a taxable party to a prohibited tax shelter
transaction must provide a statement, to any tax-exempt entity that is party to the transaction, that the transaction qualifies as a prohibited tax shelter
Only taxpayers who are qualified to participate in the IRS initiative and who complete the requirements of the program are eligible for the California initiative, wherein participants can avoid most California tax shelter
penalties, including the non-economic substance transaction understatement penalty.
Because these actions have substantially curbed tax shelter
activities, no further action is warranted.
The IRS has been developing policies to attack a variety of tax shelters
including the contingent liability shelter, in which a high-basis asset is transferred to a new corporation in exchange for stock in an IRC section 351 transaction.