that are RTs, but not RATs, remain subject to a 20-percent accuracy-related penalty under the rules of section 6662.
Taxing authorities, courts, the AICPA, and other professional organizations have struggled with defining and regulating tax shelters and abusive, transactions
. Crucial to the debate is the difficulty of clearly distinguishing between transactions
that are abusive and transactions
that are legitimate.
There currently are five categories of reportable transactions
that must be disclosed, including listed transactions
of interest--the newest category added by final regulations (TD 9350) issued on August 3, 2007 (revised final regulations).
The Department of Labor issued an updated version of its Voluntary Fiduciary Correction Program in April, adding transactions
that can be corrected under the program and expanding the ability to obtain relief from prohibited transactions
Massey Knakal announced the following transactions
It's not the first time the complicated transactions
have fallen under regulatory scrutiny, nor the first time the transactions
have been renamed.
During the past five years, the Internal Revenue Service has taken steps to combat abusive tax shelters and transactions
. The IRS seeks to put a comprehensive strategy in place to (1) identify and deter promoters of abusive tax transactions
; (2) publish guidance on transactions
and shelters that are determined to be abusive; and (3) promote disclosure by those who market and participate in abusive transactions
Decisions on incoterms, without the involvement of the transaction
tax specialist, could be a financial risk, and failure to use incoterms to help structure tax-efficient international transactions
could be an opportunity missed.
Workpapers supporting this evaluation often contain sensitive information about contingent or potential liability for transactions
whose tax treatment may not be self-evident.
While electronic commerce offers speed, convenience, and cost advantages over traditional paper-based transactions
, it raises many business and legal issues.
Conventional techniques to perform a point in time recovery will remove the effects of all transactions
since that specified point in time.