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California Takes The Initiative Against Abusive Tax Shelters ( January 2004 )
Signed into law on October 2, 2003, this new law adopts existing federal law regarding tax shelters and provides a comprehensive set of changes designed to: (1) curtail abusive tax avoidance transactions; (2) enhance penalties for investors, promoters, and organizers of abusive tax shelters, including a new penalty for transactions that lack economic substance; and (3) provide a state voluntary compliance initiative. The new legislation is generally effective January 1, 2004; however, it applies to all penalties levied after that date. -
IRS Revises Scope of Tax Shelter Regulations LimitingCoverage of Confidential Transactions ( January 2004 )
On December 29, 2003, the Treasury Department and the IRS issued revised regulations that dramatically limit the circumstances under which a confidential transaction must be disclosed under the tax shelter rules. In addition, the IRS issued new rules intended to increase transparency and disclosure of information by taxpayers to deter abusive tax avoidance transactions. -
Revenge of the Tax Lawyers? ( April 2003 )
The tax departments of most law firms have had a bad run over the last ten years, losing market share and top talent to accounting firms, but there is evidence that change is afoot. To understand the problems facing law firm tax lawyers, you have to understand the market for tax services for large corporations. -
Corporate Tax Shelters--What Will Be the Impact of the New Regulations on U.S. Multinational Corporations? ( October 2001 )
Introduction In late February of this year, the Internal Revenue Service issued three sets of temporary and propo. -
The Strategy for Curbing Abusive Corporate Tax Shelter Growth Shows Promise but could be Enhanced by Performance Measures ( September 2001 )
Abusive corporate tax shelters are sophisticated transactions often developed by tax accountants, lawyers, and other financial service providers and sold to corporations as a way to lower their tax liabilities. Even though the transactions may comply with the tax law, they typically lack a legitimate business purpose other than reducing taxes. -
The Problem of Corporate Tax Shelters ( July 1999 )
While corporate tax payments have been rising, taxes have not grown as fast as have corporate profits. One hallmark of corporate tax shelters is a reduction in taxable income with no concomitant reduction in book income. The ratio of book income to taxable income has risen fairly sharply in the last few years. Some of this decline may be due to tax shelter activity. -
U.S. Treasury Releases Proposal For Income Tax Law Changes ( January 1999 )
This article discusses and analyses the proposed tax changes in 1999 and how the proposed changes will be fundamental to well established principles of tax law.
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