The eLearning Center for Gatlin Education Services

Private practice tax attorneys and representatives from the IRS, including the chief counsel, face off in a detailed discussion of IRS enforcement efforts in the tax shelter arena. The panelists discuss general aspects of global settlement initiatives as well as specific initiatives, including those for Son of Boss transactions and non-economic residual interest (NERI) securities. They also touch upon topics such as designating cases for litigation, penalty administration, and the fast-track appeals process.

Tax Shelter Enforcement: Options for Taxpayers and Counsel
    I. Evolution of Tax Shelters and Enforcement
        A. Introduction
        B. Historical Tax Shelter Examples
        C. What Is a Tax Shelter?
        D. Government Response
        E. Tax Shelter Opinions
        F. Tax Reform Act of 1986
        G. New Tax Shelters
        H. Long Term Capital Case
    II. Recent Enforcement Efforts
        A. NERI Settlement
        B. “Son of Boss” Settlement
        C. Tax Accrual Workpapers
        D. Other IRS Initiatives
    III. Global Resolutions
        A. Speaker Introductions
        B. Overview
        C. Government Perspective
            1. Why Do Global Resolutions?
            2. The Right Balance
            3. Three Characteristics
            4. Tension Between Appeals and Global Resolutions
            5. Settlement Initiative Guidelines
            6. Successful Initiative: Son of Boss
            7. Audit Lottery Players
            8. Looking Forward
        D. Private Perspective
            1. What Is a Successful Settlement Initiative?
            2. Factors Contributing to Success
    IV. Chief Counsel’s Involvement in Enforcement
        A. A True Partnership
        B. Examination
        C. Dealing With Resistance
        D. Designating Cases for Litigation
        E. The Designation Process
        F. Statutory Notice of Deficiency
        G. Penalty Administration
        H. Clarifying IRS Stance on Penalties
    V. Fast-Track Appeals
        A. Concerns About Fast-Track Process
        B. Be Cautious
    AfterWords^SM