In the traditional sense, a tax shelter
is simply a method that a taxpayer uses to generate tax deductions and credits by investing in "investment activities" that often are not expected to generate any real profits.
The Tax Court held that the tax shelter
exception to the tax practitioner/client privilege did not apply to documents in the form of the minutes of meetings between a partnership and a federally authorized tax practitioner because the tax advice in the documents was not given in connection with the promotion of a tax shelter
A listed transaction is a reportable transaction that is the same as, or substantially similar to, a transaction specifically identified by the Treasury Department as a tax avoidance transaction; in other words, a tax shelter
determined by the IRS to be abusive and therefore unlawful.
It is my experience--including that of the recent tax shelter
initiatives--the Service also recognizes and supports our Appeals mission and our need to be independent.
Graham and Tucker (2006) examine a sample of nearly 50 tax shelter
It must stay out of the tax shelter
business and agree to restrictions on its tax practice.
To contribute to the discussion surrounding these changes, GAO's objectives were to determine (1) according to Internal Revenue Service (IRS) data, how many Fortune 500 companies obtained tax shelter
services from their auditor; (2) according to IRS data, in how many Fortune 500 companies did the auditor provide the services to individual company officers or directors; and (3) whether selected Fortune 500 case study companies changed how they obtain tax services from their auditor in recent years.
Although the IRS lost this case, it will continue to aggressively litigate any transaction considered a tax shelter
Both bills also include revenue offsets, including new tax shelter
penalties and a host of other provisions that address perceived tax abuses.
An IRS report on trends seen in tax shelter
activity; issue identification, legal guidance and analysis of shelters; and a review of current IRS tax shelter
regulation and compliance strategies were covered in the Web cast.
A tax shelter
does just what the term implies -- it shelters your other income from income tax.
Also in 1999, the Tax Court found sufficient facts to indicate that Compaq Computer engaged in an abusive tax shelter
transaction (Luscombe, 1999).