The New Penalty Regime: Proceed with Caution!

Posted: 14 Jan 2005

Abstract

This article was originally published in The Tax Executive (Nov.-Dec. 2004) and is reprinted here with permission of the Tax Executives Institute. It reviews recently enacted penalties and related statutory provisions and administrative requirements designed to strengthen the government's hand in its battle against abusive tax shelter transactions, particularly when required disclosure of those transactions is not made. Beller demonstrates that the new rules directly affect both the taxpayers and their advisers, and could in some instances result in significant changes in the nature and scope of the professional relationship between tax practitioners and their clients.

Suggested Citation

Beller, Herbert N., The New Penalty Regime: Proceed with Caution!. Available at SSRN: https://ssrn.com/abstract=648841

Herbert N. Beller (Contact Author)

Northwestern University - Pritzker School of Law ( email )

375 East Chicago Avenue
Chicago, IL 60611
United States

Sutherland Asbill & Brennan LLP ( email )

700 Sixth St., NW
Washington, DC 20001
United States
(202) 383-0120 (Phone)

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