that are not RTs (and therefore not RATs) could still have a significant purpose of tax avoidance and thus be considered "tax shelters" for accuracy penalty purposes.
For purposes of this Interpretation, tax planning includes, both with respect to prospective and completed transactions
, recommending or expressing an opinion (whether written or oral) on (a) a tax return position or (b) a specific tax plan developed by the member, the taxpayer, or a third party.
The taxpayer has entered into the listed transaction
or the transaction
of interest on or after the effective date of the 90-day rule (August 3, 2007, for listed transactions
; November 2, 2006, for transactions
Only certain types of fiduciary breaches are eligible for relief under VFC, all of which deal with transactions
involving valuation and prohibited transaction
issues under Title 1 of ERISA.
* The sale of 1520 Hart Place in the Coney Island section of Brooklyn in an all-cash transaction
valued at $885,000.
Finite reinsurance transactions
can be used to smooth the results of primary insurers as well as the earnings of non-insurance companies.
In general, sections 6011, 6111 and 6112 of the Internal Revenue Code provide "tax shelter" rules that require disclosure, registration, and list maintenance for certain transactions
. These statutory provisions and the related regulations define tax shelters, listed transactions
, and reportable transactions
* The ability to do "what-if" scenario planning, to see how specific transactions
would be taxed for better tax planning and cash management.
(3) If a return involves multiple listed transactions
, then the Service will, subject to its own discretion, request all tax accrual workpapers.
A discussion of legal issues in documenting e-commerce transactions
begins with basic questions, such as what constitutes adequate business records of an e-commerce transactions
As databases grow in size and complexity, so, too, do the chances that bad transactions
will corrupt the data on which your business depends.