The Tax Court also pointed out that PwC had no stake in the outcome of the Countryside transactions that Egan gave advice on and that the firm was paid on the same hourly basis for the advice as it was for the tax preparation services provided by Egan to the Winn organization as evidence that the advice was not the promotion of a tax shelter
The Service's tax shelter
initiatives do not limit the taxpayer's opportunities to resolve disputes; rather they expand it.
In the 1990s, nearly every big and midsize accounting firm was moving aggressively into the tax shelter
business for individuals and corporations, and the growth attracted the attention of U.
Tax professionals advising on tax shelters
who fail to register the tax shelter
are subject to a registration penalty of up to 75 percent of their gross income from providing tax shelter
Both bills impose new penalties up to $200,000 for failure to comply with existing tax shelter
disclosure regulations, and increase the penalties for underpayments related to transactions required to be disclosed under the regulations.
Although the marketing of a tax shelter
usually concentrates on the tax savings aspect of the shelter, it is vital that you, as a prospective purchaser of a tax shelter
, look first at the economics and feasibility of the investment behind the tax shelter
The primary efforts to confront the tax shelter
issue have been in the tax courts.
The IRS announced this week that approximately 2,000 taxpayers participated in the federal tax shelter
initiative that ended in January," said Board of Equalization Chair and FTB Member John Chiang.
In addition to the Form 8886-T, a tax-exempt entity and/or entity manager may be liable for excise taxes in connection with the prohibited tax shelter
The Franchise Tax Board will follow the IRS tax shelter
settlement initiative as outlined in IRS Announcement 2005-80, effectively creating the California Tax Shelter
Resolution Initiative to run alongside the federal initiative.
Boyle explained that "the key to stopping tax shelter
abuses is the effective administration of the tax law's substantive provisions," which depends, in turn, "on the ability of IRS agents to identify and analyze transactions.
Although the IRS lost this case, it will continue to aggressively litigate any transaction considered a tax shelter
The law firm of Schiffrin & Barroway announces that it is investigating improper tax shelter
schemes that major accounting firms, international banks and law firms promoted to individuals and corporations since at least the mid- 1990s.
But others can reasonably be viewed as falling in a gray area, and the courts have indeed sided with taxpayers in several tax shelter
The Franchise Tax Board (FTB) is reminding taxpayers and tax professionals that April 3, 2006, is the last day to apply for the California Tax Shelter