Archive of Initiatives Curbing Abusive Tax Avoidance Transactions


通知 :历史内容


On Sept. 24, 2004, the IRS removed a transaction involving a producer-owned reinsurance company from identification as a "listed transaction." The IRS will continue to scrutinize such transactions used to shift income to companies purporting to be insurance companies.

  • Notice 2004-65 (14K PDF) — Certain reinsurance arrangements
  • Notice 2004-67 (29K PDF) — "Listed Transactions" (revised)


The IRS received more than 1,500 applications from investors in the abusive tax shelter known as "Son of Boss" to participate in an IRS settlement initiative.


The IRS partnership with state tax administrators had uncovered tens of millions of dollars in abusive transactions by early June 2004.

In February, the IRS provided 20,000 leads to state agencies, a number that has since grown to 28,000. This activity implements September 2003 agreements to share information on taxpayers involved in abusive tax avoidance transactions.


The tax administrators of Australia, Canada, the United Kingdom and the United States have created a joint task force to coordinate the fight against abusive tax transactions.


The IRS launched a new section of its Web site, warning of abusive tax schemes involving retirement plans. (News Release) (Web section)


As 2003 drew to a close, the IRS and Treasury issued additional rules to halt abusive tax transactions.


At a hearing on Nov. 20, 2003, IRS Commissioner Everson responded to four questions about abusive tax shelter activity submitted by the Senate Governmental Affairs Committee's Permanent Subcommittee on Investigations (166K PDF).


A November 2003 summary of steps taken by the IRS and Treasury in their ongoing crackdown on abusive tax shelters.


At an Oct. 21, 2003, Senate Finance Committee hearing on corporate tax shelters, IRS Commissioner Mark Everson testified about the agency's responses and initiatives regarding abusive tax transactions (171K PDF).


In a Sept. 22, 2003, address at the Financial Services Industry Conference, Acting Chief Counsel Emily Parker explained why the alleged "Wall Street Rule" is not something for tax shelter promoters or investors to rely on ( 94K PDF).


Beginning with his nomination hearing, IRS Commissioner Mark Everson has expressed his concern about tax shelters and IRS enforcement activities.


IRS Deputy Chief Counsel (Operations) Emily Parker summarized recent IRS actions on abusive tax avoidance transactions in a June 6, 2003, address to the Texas Federal Tax Institute. (93K PDF)


Two Revenue Procedures issued Feb. 27, 2003, will make tax shelter disclosures more useful and reduce taxpayer burden by providing that certain losses and certain book-tax differences are not taken into account in determining whether a transaction is reportable.
Treatment of losses: Rev. Proc. 2003-24 (79K PDF)
Treatment of book-tax differences: Rev. Proc. 2003-25 (59K PDF)

In a Feb. 25, 2003, speech, Chief Counsel B. John Williams explained the three foundations of the IRS/Treasury approach to stopping the proliferation of tax shelters and gave an update on the three settlement initiatives announced last October. (119K PDF)

Chief Counsel B. John Williams explained the limits on attorney-client and tax practitioner privileges as regards tax shelter promoters in a June 6, 2002, address to the Texas Federal Tax Institute. (87K PDF)