Gimme … (a Tax) Shelter

Tax shelters generally follow the letter of the Internal Revenue Code but produce results that the Code never intended, such as tax losses that offset a taxpayer's capital gains or other income, often with minimal costs to the taxpayer.

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Related Content

• Tax Shelter Transactions: Penalties and Disclosure Requirements
  Learn about the types of transactions a taxpayer is required to disclose to the Internal Revenue Service based on the transaction’s perceived abusive nature. This practice note also explores the required form to make such disclosures and the penalties that can be imposed for failing to properly disclose such transactions.

• Tax Shelter Disclosure Requirements Checklist
  Reference this checklist identifying “reportable transactions” whose disclosure is required under Treas. Reg. § 1.6011-4 to promote tax shelter reporting compliance by clients who are participants or material advisors in tax shelters.

Legal Developments

• What IRS Funding Increase Means for Taxpayers
  The Inflation Reduction Act allocates nearly $80 billion in additional funds to the IRS over the next 10 years, with over half of that amount allocated specifically to enforcement. On Aug. 17, Treasury Secretary Janet Yellen requested the IRS to create a detailed plan for spending the funds allocated as part of the Inflation Reduction Act by Feb. 17, 2023. 

• Retirement Plan Sponsors Have Short 2022 Year-End Amendment List
  With IRS Notices 2022-33 and 2022-45 recently extending several plan amendment deadlines, retirement plan sponsors now have few (if any) plan amendments to adopt before 2022 draws to a close.

• LB&I Memo Providing Updated Guidance on the Statute of Limitations on Section 965 Examinations
  This article discusses the IRS Large Business and International (LB&I) division’s updated memorandum—LB&I-04-0922-0019—providing guidance regarding the extended statute of limitations for section 965 issues. 

Practical Guidance Updates 
Featuring the latest updates from your Practical Guidance account.    

• Tax Key Legal Developments Tracker (Federal)
  Stay informed on new developments: 
  • Individual Income Tax. IRS releases Revenue Procedure 2022–38, which sets forth inflation-adjusted items for 2023 for various tax provisions like the tax rate tables, standard deduction, and gift tax exclusion. 
• Document alertsallow you to stay current on legal developments that affect your practice. Find out how to set up your document alerts. 
• Check out the new Practical Guidance Author Center! Learn about the 1750+ leading attorney authors contributing to our 22 practice areas, and find out how you can Become a Practical Guidance Author.
• Share fundamental guidance with your firm’s new associates to help them sharpen their research and writing skills, get the inside scoop on associate survival, and hit the ground running in the tax practice area. Review the resources in the First Year Associate Resource Kit: Tax.
• The Practical Guidance Journal Fall Edition features impacts of the Dobbs v. Jackson Health Organization decision on employers, healthcare, insurance, and privacy concerns, and tracks the status of state law changes.
• Listen up! Access our growing collection of podcasts by navigating to the Practical Guidance Podcasts Resource Kit.

• New and Recently Updated Practical Guidance Content
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  • Hard-to-Value Intangibles
  • Permanent vs. Taxable and Deductible Temporary Differences between Book and Tax
  • International Tax Consequences of Cryptocurrency Developments
  • Moving to the United States: U.S. Tax Planning for Foreign Individuals
  • Statute of Limitations for Tax Returns (No Substantial Omissions)
  • Unauthorized Disclosure of Taxpayer Information (IRC Sections 6103 and 7431)

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