Modifications of actions to enjoin certain conduct related to tax shelters and reportable transactions.Before the AJCA AJCA American Jobs Creation Act of 2004 (US) AJCA American Jersey Cattle Association AJCA Association of Juvenile Compact Administrators AJCA All Japan Cooks Association AJCA Alabama Junior Cattlemen’s Association , Sec. 7408 authorized civil actions to enjoin To direct, require, command, or admonish. Enjoin connotes a degree of urgency, as when a court enjoins one party in a lawsuit by ordering the person to do, or refrain from doing, something to prevent permanent loss to the other party or parties. any person from promoting abusive tax shelters Abusive tax shelter A limited partnership that the IRS judges to be claiming tax deductions illegally. abusive tax shelter A tax shelter in which an improper interpretation of the law is used to produce tax benefits that are or aiding or abetting a·bet tr.v. a·bet·ted, a·bet·ting, a·bets 1. To approve, encourage, and support (an action or a plan of action); urge and help on. 2. the understatement of tax liability. New Law AJCA Section 820, modifying Sec. 7408, expands the current rules to allow an injunction to be sought against a material advisor for failing to (1) fulfill the reporting requirements for reportable and listed transactions and (2) keep investor lists. It also permits injunctions to be sought for violations of any of the rules under Circular 230. Effective Date The provision is effective on Oct. 23, 2004. FROM PAUL MANNING, WASHINGTON, DC |
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