News & Analysis as of

Tax Shelters

IRS Dirty Dozen for 2017, Tax Shelters, and Captive Insurance: Attacking Past Problems Using a Voluntary Disclosure Strategy

by Varnum LLP on

The IRS summarized its annual "Dirty Dozen" List of Tax Scams for 2017 in February. Practitioners and taxpayers should pay particular attention. The IRS is broadcasting their playbook. This list includes two principal types...more

Friends and Family and Criminal Forfeiture

by Ballard Spahr LLP on

One of the many potential consequences of a criminal conviction is that the government may seize assets held by the defendant’s family to satisfy a criminal forfeiture order against the defendant himself. In United States v....more

Client Alert: Captive Insurance on 2017 IRS “Dirty Dozen” Listing

For the third consecutive year, “abusive micro-captives” make an appearance on the IRS’ annual “Dirty Dozen” list of tax scams in 2017. Last year’s information release on abusive tax shelters, found in IR-2016-025, included...more

Mossack Fonseca Founders Arrested and Detained on Money Laundering Charges

by Ballard Spahr LLP on

The founders of Panamanian law firm Mossack Fonseca were arrested on Saturday, following their indictment on money-laundering charges allegedly tied to the ever-widening Petrobas corruption scandal in Brazil. Kenia...more

IRS Rules That Syndicated Conservation Easements With Inflated Appraisals Are Listed Transactions

by McNair Law Firm, P.A. on

In Notice 2017-10, the IRS has determined that certain conservation easements are now “listed transactions” for purposes of federal tax reporting. “Syndicated” conservation easements are conservation easements donated by a...more

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

by Coblentz Patch Duffy & Bass on

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

The Future of Credit Shelter Trusts

When the President signed the American Taxpayer Relief Act of 2012, some observers thought that certain provisions would sound the death knell for a popular legal tax shelter strategy known as Credit Shelter Trusts (CST)....more

Federal Tax Advisory: Mark to Market

by Alston & Bird on

In January 2016, the Sixth Circuit reversed the Tax Court and ruled for the taxpayer in Wright v. Commissioner, 809 F. 3d 877 (6th Cir. 2016). If the IRS agrees, the ruling means that foreign currency contracts that are...more

Focus on Tax Controversy - December 2015

by McDermott Will & Emery on

IRS Updates Administrative Appeals Process for Cases Docketed in Tax Court - In Notice 2015-72, the Internal Revenue Service (IRS) provided a proposed revenue procedure to update Rev. Proc. 87-24, 1987-1 C.B. 720, which...more

Estate Planning Pitfall - You’re selling your interest in a charitable remainder trust

Recently finalized regulations eliminate a potential tax shelter involving the sale of an interest in a charitable remainder trust. This brief article offers an example of how the tax shelter worked before the new regs and,...more

Playing With Fire: No Liability Coverage For Tax Preparers Who Took Deductions for Illegal Tax Shelters

by Carlton Fields on

“Gimme Shelter” is one of the greatest of a lot of great Rolling Stones songs (made greater by Merry Clayton’s gut-wrenching contribution). And, of course, “Gimme Shelter” is a cliché often trotted out in discussions of tax...more

IRS Issues Notices Regarding Certain Structured Transactions

by Morgan Lewis on

Parties that enter into “basket option contracts” and “basket contracts” should be aware that the IRS is likely to challenge such transactions and that they have a new obligation to report the transactions to the IRS or face...more

McNally: CRA Does Not Have Unfettered Discretion to Delay Assessment

by Dentons on

In McNally v. Canada (National Revenue) (2015 FC 767), the taxpayer brought an application to the Federal Court for an order requiring the Minister to assess his tax return. The Federal Court allowed the taxpayer’s...more

Tax Court Strikes Down “DAD” Loss Importation Tax Shelter

by Goulston & Storrs PC on

In consolidated cases known as Kenna Trading LLC, the Tax Court shut down an attempt to contribute foreign currency losses into a US partnership and syndicate the losses to investors by selling partnership interests followed...more

CRA Rocks The Boat: Garber et al. v. The Queen

by Dentons on

Readers who were tax practitioners in the mid-80s will well remember the luxury yacht tax shelters, which were sold in 1984, 1985 and 1986 and which were one of the most popular tax shelters of that period. Many of us had...more

Legal Alert: U.S. Supreme Court Resolves Circuit Split: Holds Valuation Misstatement Penalty Applies in Partnership Tax Shelter...

On December 3, 2013, the U.S. Supreme Court unanimously reversed the U.S. Court of Appeals for the Fifth Circuit and held that (1) a federal district court in a partnership-level proceeding had jurisdiction to determine the...more

The Financial Report - Volume 2, No. 22 • December 12, 2013 (Global)

by DLA Piper on

OSC to hold derivatives reporting seminar. The Ontario Securities Commission announced that it will hold a seminar on January 15, 2014, on the reporting requirements under the new Derivatives Trade Repositories and...more

Insurance Recovery Law -- Aug 07, 2013

Home Base - General Principles of Insurance Policy Interpretation -- Trends in the case law tend to catch our attention, but often practitioners and clients become sidetracked and miss the connection to the insurance...more

Focus on Tax Controversy & Litigation - July 2013

by Shearman & Sterling LLP on

In this issue: - District Court Protects Opinion Work Product Contained in Tax Accrual Workpapers in Wells Fargo - IRS Restricts Private Letter Rulings for Spin-Offs and Other Corporate Nonrecognition...more

If You Will®: Short Takes on Estates, Taxes and Trusts - May 2013

by Burns & Levinson LLP on

"IF YOU WILL®: Short Takes on Estates, Taxes and Trusts” is a quarterly glance through an informal lens at selected news items, court decisions, legislative changes and/or important issues pertinent to estate planning. It is...more

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