News & Analysis as of

Internal Revenue Code (IRC) Tax Liability Tax Shelters

Cadwalader, Wickersham & Taft LLP

Finalized Treasury Regulations Require Disclosure of Certain Micro-captive Transactions

On January 14, 2025, Treasury and the IRS published final regulations (the “Regulations”) that identify certain micro-captive insurance transactions, as well as transactions substantially similar thereto, as either listed...more

Rivkin Radler LLP

Shareholder-Transferee Liability for a Corporation’s Income Tax

Rivkin Radler LLP on

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

Gray Reed

IRS Seeks to Enforce Summons Related to Deferred Sales Trust

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We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense.  According to the IRS, these structures typically seek to defer gains associated with the sale of an appreciated asset through the use...more

Gray Reed

The IRS is Attacking Abusive Trust Arrangements

Gray Reed on

Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more

Freeman Law

Tax Court in Brief – Slone v. Commissioner

Freeman Law on

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

Freeman Law

Section 6700 Penalties – False or Fraudulent Statements

Freeman Law on

Promoting abusive tax shelters. Taxpayers and tax return preparers should be aware of the various penalties that exist and can be assessed for certain actions (or nonactions). One such action includes promoting an abusive tax...more

Gray Reed

Understanding IRS Rules on Passive Activity Losses

Gray Reed on

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

Coblentz Patch Duffy & Bass

Bipartisan House Bill Addresses Syndicated Conservation Easement Tax Shelters

Last week, Representative Mike Kelly (R) of Pennsylvania and Representative Mike Thompson (D) of California introduced the Charitable Conservation Easement Program Integrity Act of 2017 as H.R. 4459. The Act is simple;...more

Coblentz Patch Duffy & Bass

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

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

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