The IRS recently announced (News Release IR-2001-74) that Merrill Lynch agreed to settle a case related to a tax shelter
it had promoted.
continue to be the target of IRS enforcement initiatives.
But the state's 2005 amnesty program applies to all taxpayers for all tax years 2002 and prior and lacks the kind of "safe harbor" provisions found in last year's tax shelter
Daugerdas was convicted last year of helping to create tax shelters
that benefited some of the world's wealthiest investors, including the late sports entrepreneur Lamar Hunt, trust fund recipients, inventors, a grandson of the late industrialist Armand Hammer, people who built fortunes on real estate or family businesses and a man described by a prosecutor as an ''accidental millionaire'' because he was one of the earliest investors in Microsoft Corp.
While Congress has recognized that the loss of revenue is an acceptable side effect of special tax provisions designed to encourage taxpayers to make certain types of "tax shelter
" investments that yield tax benefits, losses from tax shelters
oftentimes produce little or no benefit to society, or the tax benefits are exaggerated beyond those intended.
In the Countryside case, the Tax Court held that the exception did not apply to the minutes because Egan did not give the advice they contained as part of the promotion of a tax shelter
. Noting that other courts addressing the meaning of promotion for purposes of Sec.
This tax shelter
was determined to be abusive and thus unlawful.
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?
offer a means of reducing taxes that may displace traditional sources of corporate tax deductions.
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.
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.