TEB Abusive Tax Transactions
The IRS is engaged in extensive efforts to curb abusive tax shelter schemes and transactions. The Tax Exempt and Government Entities Division of the IRS, including the office of Tax Exempt Bonds, participates in this IRS-wide effort by devoting substantial resources to the identification, analysis and examination of abusive bond transactions.
A comprehensive strategy is in place to:
- Identify and deter promoters of abusive bond transactions through audits, summons enforcement and other appropriate measures.
- Keep the Bond Community apprised of transactions and emerging issues that may be determined to be abusive.
- Promote disclosure by those who market and participate in abusive transactions.
- Develop and implement alternative methods for resolving abusive transactions.
TEB Abusive Transactions Identified
Examination of abusive transactions has been identified as an examination priority and focus area in all of the TEB work plans. This article, originally published in the FSLG Newsletter in June 2004, identifies a number of abusive schemes involving tax exempt bonds.
New Tax Law Provisions Enacted to Combat Abusive Tax Shelters
The American Jobs Creation Act of 2004 (P.L. 108-357) was signed into law by the President on October 22, 2004. This new legislation contains many provisions that will affect abusive tax shelter promotions, advisors and investors.
TEB FY2007 Work Plan
Operating priorities and program guidance for implementing the Tax Exempt Bonds portion of the TE/GE Strategic and Program Plan for fiscal year 2007.
Identifying Abusive Transactions Involving Section 501(c)(3) Organizations
and Tax-Exempt Bonds (1999)
A review of efforts to identify potentially abusive transactions involving the use of IRC 501(c)(3) organizations and tax-exempt bonds originally published in 1999.
Three Year Notes - A Tale of Too Many Cities
This article is intended to raise awareness of small issuers (including, but not limited to, school districts) regarding abusive arbitrage transactions.
Valuation of Government Securities - Yield Burning
A discussion of the valuation of the Treasury securities purchased for an advance refunding escrow and the effect an improper valuation may have on the tax-exempt status of the advance refunding issue.
IRS Corporate Abusive Tax Transactions Home Page
Listed transactions, with citations of published guidance, regulations or court cases and other useful resources.