The Resource Opinion letters offer scant shelter from tax shelter penalties

Opinion letters offer scant shelter from tax shelter penalties

Label
Opinion letters offer scant shelter from tax shelter penalties
Title
Opinion letters offer scant shelter from tax shelter penalties
Creator
Subject
Language
eng
Summary
In the case "Long Term Capital Holdings", the IRS won a dramatic and very significant victory in its war against abusive corporate tax shelters. The judge found that the extremely complex corporate tax shelter at issue in the case lacked the requisite economic substance. The judge also imposed on the taxpayers the 40% gross valuation misstatement penalty under Section 6662(h), despite the fact that the taxpayers had obtained favourable "should" level opinion letters from two very prominent law firms
Citation source
In: Practical tax strategies. - New York. - Vol. 74 (2005),
http://library.link/vocab/creatorName
Walsh, J
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • case law
  • tax shelter
  • lease stripping transaction
  • penalties
  • step transaction
  • business purpose test
  • tax avoidance
Label
Opinion letters offer scant shelter from tax shelter penalties
Instantiates
Publication
Label
Opinion letters offer scant shelter from tax shelter penalties
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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