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.
7525(b), there is an exception to the privilege for communications regarding
tax shelter transactions.
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.
See Graham and Tucker (2006) for references to other recent
tax shelter research.
KPMG earned about $124 million on those four shelters and had been fending off the government's questioning of its
tax shelter business since 1996.
IRS data available on
tax shelter services sometimes predate legislative and regulatory changes reflecting a heightened focus on auditor independence.
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.
These include provisions on
tax shelter disclosure penalties, nonqualified executive deferred compensation plans, corporate governance, Enron-related transactions, corporate inversions, individual expatriation and other perceived tax abuses.
Although perhaps not usually thought of as a
tax shelter, contributing to an RRSP is, in fact, the best known and most popular
tax shelter.
And yet another Big Five firm requires its staff to come up with one new
tax shelter idea per week to keep abreast of the competition (Novack & Saunders, 1998).
The 100 per cent
tax shelter stimulated production and the following two years saw a resurgence of feature filmmaking.
