Add to ORKGDuring 1976, Congress placed some severe restrictions on tax shelter investments. In addition, even before Congress acted, the Internal Revenue Service (IRS) initiated its own attack on tax shelters. One IRS tactic to frustrate the objectives of tax shelter investments is to shift the incidence of taxation from one entity to another. This Article focuses primarily on one phase of the IRS attacks on real estate tax shelters. We will explore the history and legal foundation of the IRS’s present position, outline alternative arguments that can be raised by a real taxpayer involved in an IRS audit, and suggest possible tax planning considerations
That the purpose of these comments is to impart basic knowledge to the legal or financial advisor wh...
Many large, multi-state retailers and banks have been acting as their own landlord by paying rent to...
This article argues that the IRS’s new proposed regulation on candidate-related political activities...
There continues to be heated discussion about tax reform in the area of real estate tax shelters. In...
During the past decade, tax shelter investments were among the most controversial planning devices u...
Tax shelters, once thought to be extinct due to the at-risk and passive activity loss rules, continu...
After briefly reviewing the so-called abusive aspects of tax shelters which led Congress to enact th...
This Comment will examine the history of nonrecourse financing and tax shelters from the fabled Cran...
The Tax Reform Act of 1976 made sweeping changes in the area of tax shelters. Real estate tax shelte...
This Article traces the development of the nonentity and agency approaches to the treatment of nomin...
This article describes the ongoing legislative and administrative efforts to curtail tax shelters. I...
This is Chapter 1 of Confidence Games (MIT, 2014). Confidence Games provides an account of the wave ...
Paul Daugerdas gained notoriety for himself and his erstwhile firm, Jenkens & Gilchrist, as the desi...
On June 25, 2020, the Internal Revenue Service (“IRS”) announced a settlement initiative (“SI”) to c...
The so-called sale and lease-back device has long been the subject of judicial and governmental scru...
That the purpose of these comments is to impart basic knowledge to the legal or financial advisor wh...
Many large, multi-state retailers and banks have been acting as their own landlord by paying rent to...
This article argues that the IRS’s new proposed regulation on candidate-related political activities...
There continues to be heated discussion about tax reform in the area of real estate tax shelters. In...
During the past decade, tax shelter investments were among the most controversial planning devices u...
Tax shelters, once thought to be extinct due to the at-risk and passive activity loss rules, continu...
After briefly reviewing the so-called abusive aspects of tax shelters which led Congress to enact th...
This Comment will examine the history of nonrecourse financing and tax shelters from the fabled Cran...
The Tax Reform Act of 1976 made sweeping changes in the area of tax shelters. Real estate tax shelte...
This Article traces the development of the nonentity and agency approaches to the treatment of nomin...
This article describes the ongoing legislative and administrative efforts to curtail tax shelters. I...
This is Chapter 1 of Confidence Games (MIT, 2014). Confidence Games provides an account of the wave ...
Paul Daugerdas gained notoriety for himself and his erstwhile firm, Jenkens & Gilchrist, as the desi...
On June 25, 2020, the Internal Revenue Service (“IRS”) announced a settlement initiative (“SI”) to c...
The so-called sale and lease-back device has long been the subject of judicial and governmental scru...
That the purpose of these comments is to impart basic knowledge to the legal or financial advisor wh...
Many large, multi-state retailers and banks have been acting as their own landlord by paying rent to...
This article argues that the IRS’s new proposed regulation on candidate-related political activities...
