Corporate Taxes, IRS, Tax Shelters

Tax Court: As to Listed Transaction, IRS Must Adhere to APA

Holland & Knight LLP on 6/13/2024

In the late 1990s and early 2000s, the IRS was confronted with a proliferation of corporate transactions that it viewed as aggressive tax shelters. Relying on the authority Congress delegated through Section 6011(a), the IRS...more

Shareholder-Transferee Liability for a Corporation’s Income Tax

Rivkin Radler LLP on 2/15/2024

Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more

BG Tax Alert - Take Two: Biden’s Budget Proposes Tax Hikes

Bailey & Glasser, LLP on 5/11/2022

On March 28, 2022, President Biden announced his 2023 federal budget (Budget), which is often referred to as the President’s Green Book. While much of the Budget harkens back to the “Build Back Better Framework” (Framework),...more

Tax Court in Brief – Slone v. Commissioner

Freeman Law on 2/14/2022

Tax Litigation: The Week of February 7 – February 11, 2022 Williams v. Commissioner Slone v. Commissioner Slone v. Comm’r, T.C. Memo 2022-6 | February 7, 2022 | Lauber, J. | Dkt. Nos. 6629-10, 6630-10, 6631-10, 6632-10...more

Understanding IRS Rules on Passive Activity Losses

Gray Reed on 7/7/2021

Several abusive tax shelters in the 1970s and 1980s caused Congress to enact rules to prevent taxpayers from deducting losses when a taxpayer doesn’t materially participate in the activity. These passive loss rules apply to...more

Antique Weapons

Alston & Bird on 10/2/2018

Some antique weapons are still dangerous; Section 269 could be one of them. Our Federal Tax Group explains why taxpayers facing Section 269 on audit should treat it seriously and what it reveals about the IRS’s hand....more

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

Coblentz Patch Duffy & Bass on 10/12/2016

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

Corporate Taxes › Internal Revenue Service › Tax Shelters