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Articles
1-100 out of 100 article(s)
| Title |
Author |
Type |
Date |
Words |
| Courts split on tax shelter exception to practitioner privilege. |
Schnee, Edward J. |
|
Sep 1, 2009 |
908 |
| Millionaires claim [euro]288m in tax relief; Call to close off tax shelters for Irish super-rich. |
|
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Aug 21, 2009 |
501 |
| Textron En banc reversal. |
|
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Aug 19, 2009 |
849 |
| Broader interpretation of economic substance blunts deductions. |
Kreissl, Laura Jean; Pulliam, Darlene |
|
Aug 1, 2009 |
542 |
| Two courts address tax shelter exception to tax practitioner privilege. |
Beavers, James |
|
Aug 1, 2009 |
1519 |
| Taxpayer 2, Government 1 In Recent Privilege And Work-Product Disputes: Countryside v. Commissioner, Valero Energy Corp. v. United States, And United States v. Deloitte & Touche. |
|
Case overview |
Jul 5, 2009 |
2656 |
| Tax shelter transactions disregarded. |
Beavers, James |
|
Jul 1, 2009 |
1562 |
| Seeking tax shelter following split-up. |
|
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Jul 1, 2009 |
117 |
| Feds peg Seattle firm's tax shelters as tax dodge. |
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Jun 4, 2009 |
540 |
| Tax haven purge ends with a fudge. |
|
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Apr 3, 2009 |
428 |
| Notice 2008-111: recent guidance on intermediary transactions. |
Fiesta, Susan F. |
|
Mar 1, 2009 |
1663 |
| Patenting tax strategies: what it means for the accounting profession: imagine filing your company's or your client's tax return. Weeks later, you receive notice that ACME tax services is suing you for patent infringement. This is the possibility with patented tax strategies. Several pieces of legislation are pending to remedy the situation. In the meantime, what does this mean for CPAs? |
Kowalski, Lawrence W.; Schauer, Paul C. |
|
Jan 1, 2009 |
3016 |
| DOJ Targets Approximately 20,000 Investors As Co-Conspirators In Criminal Tax Fraud Investigation Of UBS. |
|
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Dec 3, 2008 |
523 |
| "Significant purpose" of tax avoidance trumps document privilege. |
Elzweig, Brian |
|
Dec 1, 2008 |
500 |
| A $200,000 penalty for a $25,000 deduction??!! - the high price of failing to disclose listed transactions under section 6707A of the code. |
Ruchelman, Charles M.; Carney, Leila D. |
|
Nov 11, 2008 |
2079 |
| Economic substance redux. |
Schnee, Edward J. |
|
Nov 1, 2008 |
732 |
| Hong Kong: Korea may reapply tax to overseas equity funds. |
|
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Aug 5, 2008 |
595 |
| LILO comes up one leg short. |
Schnee, Edward J. |
|
Aug 1, 2008 |
544 |
| Equal treatment for all taxpayers. |
Gilman, Jeffrey |
|
Aug 1, 2008 |
378 |
| Government loses son of boss tax shelter case. |
Nevius, Alistair M. |
|
Jul 1, 2008 |
368 |
| Forms 8275 and 8275-R: how much information is enough? |
Hodes, Rochelle L.; Fernandez, Lewis J. |
|
Jul 1, 2008 |
1016 |
| Tax Court vacates stipulated decisions in tax shelter case. |
Beavers, James |
|
Jul 1, 2008 |
1684 |
| The pursuit of transparency does not trump the work product privilege. |
Henkel, Michelle M. |
|
May 1, 2008 |
7410 |
| The issue focus approach after one year: can LMSB steer clear of the shelter paradigm? |
Blair, David B.; Hani, George A. |
|
May 1, 2008 |
6202 |
| Risk, return, and objective economic substance. |
Luke, Charlene D. |
|
Mar 22, 2008 |
20736 |
| Economic substance prevails against another son of BOSS. |
Upshaw, Alice A.; Pulliam, Darlene |
|
Mar 1, 2008 |
621 |
| CPAs at risk as government continues to attack abusive tax shelters. |
McGowan, John R. |
|
Mar 1, 2008 |
4460 |
| Codification of the economic substance doctrine. |
Beavers, James |
|
Mar 1, 2008 |
1799 |
| Offshore tax havens a target. |
|
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Mar 1, 2008 |
177 |
| CRA suspends charity, tax shelter audit planned. |
|
|
Jan 23, 2008 |
251 |
| Administration. |
|
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Jan 1, 2008 |
1260 |
| Alternative tax wasn't aimed at middle class; Q&A; Why is the AMT a problem?; Am I vulnerable? |
|
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Nov 10, 2007 |
402 |
| Two Recent Tax Shelter Decisions Require Supreme Court Clarification. |
Woo, Tracey |
|
Nov 2, 2007 |
1816 |
| Son of boss goes into overtime. |
Schnee, Edward J. |
|
Nov 1, 2007 |
594 |
| Congress continues to focus on tax-shelter activity. |
Prysock, Mark |
|
Nov 1, 2007 |
754 |
| KPMG three's tax shelter trial to start. |
|
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Oct 8, 2007 |
112 |
| I text my accountant: 'Gimme Tax Shelter'; THE JAGGER DIARIES. |
|
Column |
Jun 14, 2007 |
482 |
| No penalty for BLIPS. |
Schnee, Edward J. |
|
Jun 1, 2007 |
496 |
| Sidley Austin Settles Government Tax Shelter Investigations. |
|
|
May 23, 2007 |
436 |
| Golden State owner fighting the IRS; Notebook. |
|
|
May 18, 2007 |
422 |
| IRS, B&D tool up for trial. |
Pulliam, Darlene |
|
May 1, 2007 |
458 |
| Tax controversy in the post-shelter era. |
Gibbs, Lawrence B. |
|
May 1, 2007 |
3477 |
| LMSB's industry issue focus approach: applying lessons learned from battling tax shelters to mainstream tax issues. |
Blair, David B.; Hani, George A. |
|
May 1, 2007 |
6653 |
| Tax-sheltered investment accounts: fund yours now, retire later. |
|
|
May 1, 2007 |
397 |
| IRS scores victory over alleged tax shelter. |
Pulliam, Darlene |
|
Apr 1, 2007 |
656 |
| State tax shelters and state taxation of capital. |
Bankman, Joseph |
|
Mar 22, 2007 |
8270 |
| State tax shelters and U.S. fiscal federalism. |
Stark, Kirk J. |
|
Mar 22, 2007 |
3174 |
| In defense of tax shelters. |
Katz, Leo |
|
Mar 22, 2007 |
6127 |
| In defense of requiring back-flips. |
Shaviro, Daniel N. |
|
Mar 22, 2007 |
1691 |
| Compaq redux: implicit taxes and the question of pre-tax profit. |
Knoll, Michael S. |
|
Mar 22, 2007 |
15937 |
| Tax shelters, Dutch books, and the fundamental theorem of asset pricing. |
Chorvat, Terrence R. |
|
Mar 22, 2007 |
8660 |
| Tax shelters and the Code: navigating between text and intent. |
Dean, Steven A.; Solan, Lawrence M. |
|
Mar 22, 2007 |
11071 |
| Of lenity, Chevron, and KPMG. |
Hickman, Kristin E. |
|
Mar 22, 2007 |
16704 |
| Disrupting the market for tax planning. |
Weisbach, David A. |
|
Mar 22, 2007 |
3410 |
| Patents, tax shelters, and the firm. |
Burk, Dan L.; McDonnell, Brett H. |
|
Mar 22, 2007 |
9644 |
| Questioning the wisdom of patent protection for tax planning. |
Hellwig, Brant J. |
|
Mar 22, 2007 |
11641 |
| Options backdating, tax shelters, and corporate culture. |
Fleischer, Victor |
|
Mar 22, 2007 |
13800 |
| Tax lawyers are people too. |
Hill, Claire A. |
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Mar 22, 2007 |
1365 |
| American admits fraud over KPMG tax shelters. |
|
|
Dec 22, 2006 |
268 |
| A successful season: CalCPA makes its presence known in the capitol. |
Allen, Bruce C. |
|
Oct 1, 2006 |
844 |
| Interpretative theory and tax shelter regulation. |
Galle, Brian |
|
Sep 22, 2006 |
21072 |
| New Excise Taxes and Disclosure Rules With Respect to Potentially Abusive Tax Shelter Transactions Involving Tax-Exempt Entities. |
Serota, Susan |
|
Aug 11, 2006 |
1321 |
| Quellos Group says it is subject of IRS inquiry. |
|
|
Aug 10, 2006 |
352 |
| Saban endures grilling by Senate for acceptance of bogus tax shelter. |
Riley-Katz, Anne |
|
Aug 7, 2006 |
338 |
| Trillions in assets hidden offshore, report says; Havens for rich; Senate study says wealthy are dodging billions in taxes. |
|
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Aug 1, 2006 |
431 |
| Pressuring KPMG to Cut Off Advancement of Fees of Employees in Criminal Tax Shelter Investigation Violates Constitutional Rights. |
|
|
Jul 31, 2006 |
536 |
| Pattern evidence in tax shelter litigation. |
Trainer, Corina |
|
Jul 1, 2006 |
799 |
| Chief Counsel revamps case-specific advice procedures to match LMSB's new enforcement paradigms. |
Mersereau, Dwight N. |
|
Jul 1, 2006 |
5608 |
| Tax Executives Institute-U.S. Department of Treasury Office of Tax Policy Liaison meeting minutes. |
|
|
May 1, 2006 |
4568 |
| Abusive tax transactions involving exempt organizations. |
Underwood, Joyce M. |
|
May 1, 2006 |
906 |
| No significant problems arise during 2006 tax filing season, AICPA tells Congress. |
|
|
May 1, 2006 |
447 |
| State Warns IRS Participants; FTB Urges IRS Tax Shelter Initiative Participants to Make Full Disclosure. |
|
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Mar 29, 2006 |
485 |
| Franchise Tax Board Says Deadline Looming for California Tax Shelter Resolution Initiative; Taxpayers Stand to Save Millions. |
|
|
Mar 20, 2006 |
446 |
| Timeline shows stronger scrutiny by IRS of cheats. |
Rozbruch, Michael |
Chronology |
Mar 13, 2006 |
321 |
| FTB follows IRS tax shelter initiative. |
|
Brief article |
Mar 1, 2006 |
88 |
| Hedge identification and timing rules - traps for the unwary. |
Ricks, Jo Lynn |
|
Mar 1, 2006 |
2028 |
| HVB and US Attorney/IRS Reach Agreement in Tax Shelter Investigation. |
|
|
Feb 14, 2006 |
405 |
| Amendments to circular 230. |
Kastantin, Joseph T. |
|
Feb 1, 2006 |
5233 |
| State of the Union: Stanford Economists Voice Doubts About Potential Health-Care Proposal; White House Proposal Seen as Tax Shelter for the Wealthy with No Lasting Impact on Health-Care Crisis. |
|
|
Jan 27, 2006 |
789 |
| California Follows IRS Tax Shelter Initiative. |
|
|
Jan 11, 2006 |
415 |
| WOOLLY WORLD ALPACAS PROVE TO BE MORE THAN TAX SHELTER. |
|
|
Jan 2, 2006 |
750 |
| Amendments to circular 230: this two-part article analyzes additions and amendments to the circular 230 regulations adopted in 2004 and 2005. Part 1 covers rules on best practices and the definition of covered opinions. |
Kastantin, Joseph T. |
|
Jan 1, 2006 |
6624 |
| Deferred prosecution agreements: implications for corporate tax departments. |
Thorn, Kevin E. |
|
Jan 1, 2006 |
5463 |
| Circular 230: is the hysteria over? |
MacIvor, Alexis A. |
|
Jan 1, 2006 |
5767 |
| Comments on revenue offset provisions in Senate tax reconciliation bill: January 10, 2006. |
|
|
Jan 1, 2006 |
1709 |
| TEI encourages IRS to reaffirm independence of Appeals: January 17, 2006. |
|
|
Jan 1, 2006 |
672 |
| Circular 230: beware the Jabberwock! |
Tell, Meah Rothman |
|
Jan 1, 2006 |
5355 |
| Tax advice before the return: the case for raising standards and denying evidentiary privileges. |
Beale, Linda M. |
|
Jan 1, 2006 |
38091 |
| Worst tax shelter. |
|
|
Dec 26, 2005 |
57 |
| Worst tax shelter II. |
|
|
Dec 26, 2005 |
39 |
| Bridging the book-tax accounting gap. |
Whitaker, Celia |
|
Dec 1, 2005 |
20031 |
| IRS Tax Shelter Settlement Initiative. |
|
|
Nov 30, 2005 |
2612 |
| Reflections on practicing tax in today's world. |
Gibbs, Lawrence B. |
|
Nov 1, 2005 |
3453 |
| TEI comments on Multistate Tax Commission draft model uniform statute: September 27, 2005. |
|
|
Nov 1, 2005 |
2851 |
| More partners charged in KPMG tax fraud probe; CITY BRIEFING. |
|
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Oct 18, 2005 |
625 |
| More partners charged in KPMG tax fraud probe. |
|
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Oct 18, 2005 |
384 |
| 10 more indicted in KPMG tax case; Bogus tax shelters; Feds say $2.5 billion in payments evaded. |
|
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Oct 18, 2005 |
311 |
| Beating the "wrap": the agency effort to control wraparound insurance tax shelters. |
Luke, Charlene Davis |
|
Jun 22, 2005 |
33636 |
| TEI comments on LMSB record retention initiative: April 8, 2004. |
|
|
May 1, 2004 |
1047 |
| Asset allocation and Section 529 plans. |
DeGennaro, Ramon P. |
|
Mar 22, 2004 |
3572 |
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