The first set of regulations [issued under IRC section 6111(d)] requires
tax shelter promoters to register with the IRS transactions that are structured for a significant purpose of tax avoidance or evasion, are offered to corporate participants under conditions of confidentiality, and for which the
tax shelter promoter receives fees in excess of $100,000 (Temporary Regulations section 301.6111-2T).
The Department of the Treasury's campaign against corporate "
tax shelters is attempting to convict corporate America of massive tax abuse.
* In 2005, the IRS continued its strategy of offering settlements to taxpayers involved in various
tax shelters.
(1) Other congressional actions, such as passage of the Sarbanes-Oxley Act, and the rulemaking and enforcement activities of the Securities and Exchange Commission and the Public Company Accounting Oversight Board pursuant to the authority granted by that Act have complemented the Treasury Department and IRS's efforts to curb
tax shelters. For example, the PCAOB has adopted independence rules that severely restrict the tax advice that accountants may render to their audit clients.
This program differs from the state's 2004
tax shelter amnesty program in several ways.
NEW YORK -- A Chicago-area lawyer and accountant labeled by the government as history's most prolific and unrepentant tax cheat was sentenced Wednesday to 15 years in prison, and the judge bemoaned the ''incredible greed'' of some of America's wealthiest people for taking advantage of the
tax shelters he peddled.
The
tax shelter vehicle, such as an equipment leasing venture, may use the accelerated cost recovery system or accelerated depreciation with respect to the cost of the property.
When making investment choices the decisions can be between the types of
tax shelter you invest in versus the potential fund performance within that
tax shelter.
Countryside argued that it was not required to produce the documents because the IRS had failed to prove that minutes were related to the promotion of a corporation's participation in any
tax shelter, so the Sec.
The court noted that under section 7525(b), the privilege does not apply to written communication "in connection with the promotion of the direct or indirect participation" of a corporation in a
tax shelter as defined in section 6662(d)(2)(C)(ii).
Andy is engaged in a partnership transaction as a
tax shelter that results in tax benefits on his income tax returns filed on April 15 of 2006 and 2007, but he failed to disclose the required tax-shelter information in the return.
I can assure you, Appeals is fulfilling its role in all of the internal discussions surrounding the
tax shelter initiatives.
