Corporate Tax Shelters: Looking Under the Roof : Hearing Before the Committee on Finance, United States Senate, One Hundred Seventh Congress, Second Session, March 21, 2002 |
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abusive tax avoidance abusive tax shelters abusive transactions accuracy-related penalty addition advisors appropriate BAUCUS Bermuda CHAIRMAN Chief Counsel Circular 230 Code combat abusive tax Committee Compaq complex compliance corporate tax shelters corporate taxpayers Department's Enforcement Proposals disclose reportable transactions disclosure initiative disclosure requirements disclosure rules economic substance ensure evaluate failure to disclose identify income Internal Revenue Code Internal Revenue Service investor lists judicial doctrines LANGDON legislative proposals list maintenance requirements listed transaction lists of investors litigation LMSB MAX BAUCUS OECD Office of Chief Office of Tax offshore offshore financial centers OTSA participating published guidance questionable transactions Reason for Proposal registration and list result Senator GRAHAM Senator GRASSLEY strict liability summonses task forces tax avoidance transactions tax benefits tax haven tax laws tax opinion Tax Shelter Analysis tax system taxpayers and promoters transparency Treasury Department believes Treasury Department's Enforcement types of transactions U.S. tax underpayment WEINBERGER
Popular passages
Page 52 - ... legal right of a taxpayer to decrease the amount of what otherwise would be his taxes, or altogether avoid them, by means which the law permits, cannot be doubted.
Page 73 - OECD initiative, however, must be refocused on the core element that is our common goal: the need for countries to be able to obtain specific information from other countries upon request in order to prevent the illegal evasion of their tax laws by the dishonest few. In its current form, the project is too broad and it is not in line with this Administration's tax and economic priorities.
Page 2 - A more light-hearted definition of a shelter as "a deal done by very smart people that, absent tax considerations, would be very stupid" has been attributed to Professor Michael Graetz (Department of the Treasury, 1999: v). Professor Calvin Johnson has given this thought more precision: "a tax shelter is an investment that is worth more after-tax than before-tax" (quoted in Johnston, 2003: 220). The definition of aggressive tax planning...
Page 1 - We are working through a lot of companies who feel that it is, that just the improvement on earnings is powerful enough that maybe the patriotism issue needs to take a back seat to that.
Page 7 - I just ask that it be put in the record. The CHAIRMAN. It will be. [The prepared statement of Senator Harkin follows:] STATEMENT OF SENATOR TOM HARKIN Thank you Mr.
Page 109 - The regulations clarify that the term "substantially similar" includes any transaction that is expected to obtain the same or similar types of tax consequences and that is either factually similar or based on the same or similar tax strategy.
Page 92 - The fourth category of reportable transactions relates to any transaction resulting in a taxpayer claiming a loss (under section 165) of at least (1) $10 million in any single year or $20 million in any combination of years by a corporate taxpayer or a partnership with only corporate partners...
Page 70 - DEPARTMENT OF THE TREASURY OFFICE OF PUBLIC AFFAIRS FOR IMMEDIATE RELEASE Contact: Anne Womack Kolton March 23, 2004 (202) 622-2960 HEARING TESTIMONY THE HONORABLE JOHN W.
Page 48 - In addition to the statutory provisions, courts have developed several doctrines that can be applied to deny the tax benefits of tax motivated transactions, notwithstanding that the transaction may satisfy the literal requirements of a specific tax provision. The common-law doctrines are not entirely distinguishable, and their application to a given set of facts is often blurred by the courts and the IRS. Although these doctrines serve an important role in the administration of the tax system, invocation...
Page 11 - I do have the extended remarks that hopefully will be part of the record. The CHAIRMAN. It will be. [The prepared statement of Mr.