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.
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