Tax Law News and Insights

When the Internal Revenue Service (IRS) seeks compliance from a taxpayer with an outstanding tax balance, it has many enforced collection tools at its disposal, including the suspension of a person's passport. This is done through the IRS Passport Denial and Revocation program and is in addition to the agency's...

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The Treasury Department and IRS have just published proposed Regulations that would identify transactions resembling certain basket contract transactions as listed transactions per the meaning of Section 6011, making them reportable transactions. A "listed transaction" is a transaction that is the same as or substantially similar to one of the...

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In the article that appeared in last month's blog, I indicated that we utilize a structure that avoids the taxing authorities' challenges to "drop and swap" transactions and, instead, that is structured to comply with an Internal Revenue Code provision and the Treasury Regulations. The transaction is known as a "partnership...

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