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
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
A “qualified amended return” is an amended tax return that, if properly filed before a taxpayer is “on the IRS’s radar,” protects a taxpayer against accuracy-related penalties—in layman’s terms, it is a get-out-of-jail-free...more
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