News & Analysis as of

Internal Revenue Code (IRC) Tax Shelters Tax Planning

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

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

Carlton Fields

Recent Tax Shelter Disclosure Requirements in Mexico and Argentina

Carlton Fields on

Emboldened by new laws, tax authorities worldwide are ramping up efforts to require tax advisors and taxpayers to provide enhanced information regarding tax schemes. Armed with additional disclosures, authorities are becoming...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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