Download or read book Accuracy Related Penalties for Taxpayers Involved in Tax Shelter written by Internal Revenue Service and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Report to the Congress on Penalty and Interest Provisions of the Internal Revenue Code written by and published by . This book was released on 1999 with total page 182 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Penalty and Interest Provisions in the Internal Revenue Code written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 2000 with total page 288 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Study of Present law Penalty and Interest Provisions as Required by Section 3801 of the Internal Revenue Service Restructuring and Reform Act of 1998 including Provisions Relating to Corporate Tax Shelters written by and published by . This book was released on 1999 with total page 672 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Civil Tax Penalties Reform written by Michael I. Saltzman and published by . This book was released on 1990 with total page 406 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Collection Process income Tax Accounts written by United States. Internal Revenue Service and published by . This book was released on 1978 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Tax Shelter Disclosure and Penalties written by Mary A. McNulty and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: One of the primary weapons in the battle against tax shelters has been mandatory disclosure to the IRS. The American Jobs Creation Act of 2004 built on this approach by clarifying and making consistent the various disclosure requirements and strengthening penalties for non-disclosure. To uncover abusive transactions, Congress drew the boundaries of disclosure so broadly that even legitimate tax planning transactions are covered. To understand the dangers in the new rules, one must look at the broad range of transactions covered, the participants covered, and the harsh penalties for nondisclosure. - Transactions Covered. The disclosure requirements apply to six categories of "reportable transactions." Although the Service has established "angel lists" excluding some transactions from the broad definitions, many clearly legitimate transactions still will have to be disclosed. - Participants Covered. The disclosure requirements apply to participants in the transaction and material advisors, which are also broadly defined terms. For example, an exempt organization that is an accommodation party in a reportable transaction is a participant, even though the exempt organization does not receive any tax benefits from the transaction. - Penalties. The Act added a new penalty for a taxpayer's failure to disclose a reportable transaction. This penalty applies even if a court rejects the Service's view of the tax treatment of the transaction. The Act also strengthened the accuracy-related penalty for underpayments. However, this penalty is imposed only if the Service successfully challenges the tax treatment of the transaction. The new tax shelter disclosure and list maintenance requirements are complex, with significant penalties for non-compliance. The IRS is likely to apply these penalties strictly and aggressively. Anyone involved in virtually any capacity in any substantial transaction will need to evaluate their exposure carefully.
Download or read book Why People Pay Taxes written by Joel Slemrod and published by . This book was released on 1992 with total page 361 pages. Available in PDF, EPUB and Kindle. Book excerpt: Experts discuss strategies for curtailing tax evasion
Download or read book The Case Against a Strict Liability Economic Substance Penalty written by Kathleen DeLaney Thomas and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The latest wave in tax shelter reform is the recent codification of the so-called “economic substance doctrine” and the accompanying strict liability penalty for violations of the doctrine. The new strict liability penalty has been criticized by tax scholars and practitioners for being unfair and disproportionate. However, most commentators have not evaluated whether there is any need for a separate penalty for violations of the economic substance doctrine at all, strict liability or otherwise. The first part of this Article considers the new economic substance penalty in light of the current penalties applicable to tax shelters and argues that a separate penalty provision for violations of the economic substance doctrine should not have been enacted. This Article will demonstrate that the current accuracy-related penalty regime is sufficient to address transactions that violate the economic substance doctrine and that the new penalty adds significant and undue complexity to the current regime. This Article will then explore the strict liability aspect of the penalty and consider whether there is any justification for carving out transactions that violate the economic substance doctrine as especially deserving of strict liability as compared to other tax shelter transactions. Congress's justifications for the new strict liability penalty largely focus on taxpayer deterrence and reducing disadvantages to the IRS in enforcing penalties. However, Congress has failed to articulate why violations of the economic substance doctrine have been singled out for strict liability when other tax shelter penalties contain taxpayer defenses. The only way to properly justify a new tax shelter penalty with strict liability would be to tie that penalty to the most egregious forms of taxpayer misconduct, but there appears to be no link between violations of economic substance and the worst kinds of tax shelters. Given that violations of the economic substance doctrine are not a proxy for the most abusive tax shelter transactions, this Article concludes that the imposition of a strict liability penalty cannot be reconciled with other tax shelter penalties that provide for various forms of a reasonable cause defense.
Download or read book Options to Improve Tax Compliance and Reform Tax Expenditures written by United States. Congress. Joint Committee on Taxation and published by Joint Committee on Taxation. This book was released on 2005 with total page 450 pages. Available in PDF, EPUB and Kindle. Book excerpt: Describes proposals to to reduce the size of the Federal tax gap by curtaling tax shelters, closing unintended loopholes, addressing other areas of noncompliance with current tax law, and reforming certain areas of tax expenditures.
Download or read book Farmer s Tax Guide written by and published by . This book was released on 1998 with total page 112 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Statement of Procedural Rules written by United States. Internal Revenue Service and published by . This book was released on 1980 with total page 12 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Crisis in Tax Administration written by Henry Aaron and published by Rowman & Littlefield. This book was released on 2004-05-20 with total page 420 pages. Available in PDF, EPUB and Kindle. Book excerpt: People pay taxes for two reasons. On the positive side, most people recognize, even if grudgingly, that payment of tax is a duty of citizenship. On the negative side, they know that the law requires payment, that evasion is a crime, and that willful failure to pay taxes is punishable by fines or imprisonment. The practical questions for tax administration are how to strengthen each of these motives to comply with the law. How much should be spent on enforcement and how should enforcement be organized to promote these objectives and achieve the best results per dollar spent? Over the last few years, the U.S. Congress has restricted spending on tax administration, forcing the Internal Revenue Service to curtail enforcement activities, at the same time, that the number of individual filers has increased, tax rules have become more complex, and more business have become multinational operations. But if too many cases of tax evasion go undetected and unpunished, those who may have grudgingly paid their taxes may soon find it easier to join the scofflaws. These events in combination have created a genuine crisis in tax administration. The chapters in this volume evaluate the capacity of authorities to enforce the tax laws in a modern, global economy and examine the implications of failing to do so. Specific aspects of tax law, including tax shelters, issues relating to small businesses, tax software, role of tax preparers, and the objectives of tax simplification are examined in detail. The volume also builds a conceptual basis for future scholarship, with regard not only to tax administration, but also to such fundamental questions as whether taxpayers respond mostly to economic incentives or are influenced by their experiences with the filing process and what is the proper framework for evaluating the allocation of resources within the IRS.
Download or read book General Explanation of Tax Legislation Enacted in written by and published by Government Printing Office. This book was released on 2005 with total page 652 pages. Available in PDF, EPUB and Kindle. Book excerpt: JCS-5-05. Joint Committee Print. Provides an explanation of tax legislation enacted in the 108th Congress. Arranged in chronological order by the date each piece of legislation was signed into law. This document, prepared by the staff of the Joint Committee on Taxation in consultation with the staffs of the House Committee on Ways and Means and the Senate Committee on Finance, provides an explanation of tax legislation enacted in the 108th Congress. The explanation follows the chronological order of the tax legislation as signed into law. For each provision, the document includes a description of present law, explanation of the provision, and effective date. Present law describes the law in effect immediately prior to enactment. It does not reflect changes to the law made by the provision or subsequent to the enactment of the provision. For many provisions, the reasons for change are also included. In some instances, provisions included in legislation enacted in the 108th Congress were not reported out of committee before enactment. For example, in some cases, the provisions enacted were included in bills that went directly to the House and Senate floors. As a result, the legislative history of such provisions does not include the reasons for change normally included in a committee report. In the case of such provisions, no reasons for change are included with the explanation of the provision in this document. In some cases, there is no legislative history for enacted provisions. For such provisions, this document includes a description of present law, explanation of the provision, and effective date, as prepared by the staff of the Joint Committee on Taxation. In some cases, contemporaneous technical explanations of certain bills were prepared and published by the staff of the Joint Committee. In those cases, this document follows the technical explanations. Section references are to the Internal Revenue Code unless otherwise indicated.
Download or read book IRS Practice and Procedure written by Michael I. Saltzman and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The Role of Professional Firms in the U S Tax Shelter Industry written by United States. Congress. Senate. Committee on Homeland Security and Governmental Affairs. Permanent Subcommittee on Investigations and published by . This book was released on 2005 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Jumpstart Our Business Strength JOBS Act written by United States. Congress. Senate. Committee on Finance and published by . This book was released on 2003 with total page 256 pages. Available in PDF, EPUB and Kindle. Book excerpt:
