Looking for opportunities to reduce tax liability is common. There is nothing wrong with seeking to reduce tax exposure. The late Judge Learned Hand is famous for a commonly quoted opinion from the Second Circuit Court of Appeals, saying: “Anyone may arrange his affairs so that his taxes shall be as low as possible; he…
Read More
Treasury recently finalized regulations imposing significant reporting obligations on persons involved in what the regulations describe as “related party basis adjustment transactions.” These regulations designate such transactions as “transactions of interest,” a form of reportable transactions.[1] Reporting obligations can apply to transactions completed prior to the date of these regulations and also may extend many,…
Read More
In a recent full Tax Court opinion[1], the Tax Court set aside Notice 2017-10, holding IRC § 6662A penalties are not to be imposed upon the taxpayer.[2] The Court’s reasoning was that the IRS failed to properly follow the notice-and-comment procedure, required under the Administrative Procedure Act. On December 23, 2016, the IRS issued Notice…
Read More