Tax shelter disclosures.According to according to prep. 1. As stated or indicated by; on the authority of: according to historians. 2. In keeping with: according to instructions. 3. IR-2002-22, midway through the 120-day "window of opportunity" for disclosing tax shelter tax shelter: see tax exemption. transactions, the IRS An abbreviation for the Internal Revenue Service, a federal agency charged with the responsibility of administering and enforcing internal revenue laws. has taken new steps to protect a taxpayer's right to assert attorney-client and work-product privileges when voluntarily disclosing shelter transactions. On Dec. 21, 2001, the IRS started a 120-day window of opportunity for taxpayers to voluntarily disclose tax shelters and other questionable items reported on returns. According to the Service, 21 taxpayers thus far have disclosed more than $1 billion in claimed losses under this initiative. The disclosure initiative is part of an IRS and Treasury effort to identify and curtail cur·tail tr.v. cur·tailed, cur·tail·ing, cur·tails To cut short or reduce. See Synonyms at shorten. [Middle English curtailen, to restrict shelter activity. Information obtained through disclosures helps the IRS more readily identify unregistered shelter promoters and find other taxpayers who have not disclosed their shelter participation. The IRS hopes to encourage taxpayers to disclose shelters and other questionable items potentially resulting in a tax underpayment, by waiving certain accuracy-related penalties. A taxpayer need not agree that the disclosed shelter or item resulted in an underpayment to avoid penalties. Taxpayers who make disclosures must, among other things, describe the transaction's material facts, provide the names and addresses of the promoters who solicited their participation, provide on request copies of materials and documents related to the transaction or item, and sign a penalty-of-perjury statement as to the accuracy of the information provided. The IRS will waive To intentionally or voluntarily relinquish a known right or engage in conduct warranting an inference that a right has been surrendered. For example, an individual is said to waive the right to bring a tort action when he or she renounces the remedy provided by law for such the accuracy-related penalty for tax underpayments attributable to one or more of the following: * Negligence. * Substantial understatement of income tax. * Certain substantial valuation mis-statements. * Substantial overstatement o·ver·state tr.v. o·ver·stat·ed, o·ver·stat·ing, o·ver·states To state in exaggerated terms. See Synonyms at exaggerate. o of pension liabilities Pension liabilities Future liabilities resulting from pension commitments made by a corporation. Accounting for pension liabilities varies widely by country. . The disclosure initiative does not apply to taxpayers involved in fraud, criminal conduct, concealment of a foreign financial account or foreign trust or deduction of personal expenses as business expenses. Disclosure creates no inference (logic) inference - The logical process by which new facts are derived from known facts by the application of inference rules. See also symbolic inference, type inference. that the taxpayer treated the item improperly or that the accuracy-related penalty will apply. The IRS encourages taxpayers who have reported questionable items on their tax returns to come forward. To make a disclosure, taxpayers should submit the disclosure information to their assigned IRS Team Manager or, if not under Examination, to: IRS Office of Tax Shelter Analysis LM:PFTG:OTSA 1111 Constitution Ave, NW Washington, DC 20224 See Ann. 2002-2, available at www.irs.gov; for more information, call the IRS Office of Tax Shelter Analysis at (202) 283-8425. |
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