Topic
Tax Avoidance
127 published works
Wills, Trusts & Estates Prof Blog
IRS Final Rules Identify Syndicated Conservation Easements as Abusive Tax Transactions
The IRS and U.S. Treasury Department have finalized regulations identifying certain syndicated conservation easement transactions as "listed transactions," marking them as abusive tax schemes that must be reported. Released on…
Dollars & Sense
IRS Further Combats Basket Contract Transactions with Proposed Regs
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…
India Tax Law
First judgment on GAAR holds bonus-stripping to be an impermissible tax-avoidance arrangement
By S.R. Patnaik, Thangadurai V.P
The provisions of General Anti-Avoidance Rules (“GAAR”) were implemented into Income Tax Act, 1961 (“IT Act”), for the first time with effect from the financial year 2017–18. The GAAR provisions…
Allens Insights
(WIP) Tax Benefits and Desire: lessons from the Minerva
By Allens
The Full Federal Court decision 9 min read The Full Federal Court decision of Minerva Financial Group Pty Ltd v Commissioner of Taxation [2024] FCAFC] 28 allowed the taxpayer's appeal,…
The CLS Blue Sky Blog
Tax Avoidance Through Cross-Border Mergers and Acquisitions
By Jean-Marie Meier, Jake Smith
In a new paper, we examine the extent to which cross-border M&A is influenced by tax avoidance motives and quantify the resulting tax savings. Firms employ tax avoidance strategies like…
Beneficially Yours
FICA Tax Avoidance Wellness Program Viewed Unfavorably by 87,000 New IRS Agents
Seyfarth Synopsis: Just like a bad penny, schemes promising employers ways to reduce their FICA tax burden, and maybe their employees’ income tax burden at the same time, keep popping…
Canadian Lawyer Mag
SCC finds company committed abusive tax avoidance in case dealing with general anti-avoidance rule
Decision deals with Income Tax Act provision restricting when business losses can offset tax burden
TaxSlaw
The Federal Attack on Grantor Trusts: The Demise of Basis Step-Up at Death?
By Louis Vlahos
Don’t Wait for Us On March 20, 2023, Senators Warren, Sanders, Van Hollen, and Whitehouse addressed a letter to Treasury Secretary Yellen in which they urged Yellen “to use [her]…
European Union and Italian International Tax Law Blog
Italian Taxation of Trusts: Tax Agency Rules that Settlor’s Unconditioned Power To Remove and Replace Guardian Makes the Trust Fiscally Interposed, Nonexistent For Tax Purposes
By Marco Rossi
In its ruling no. 267, dated March 27, 2023 (Risposta-n.-267_2023.pdf), the Italian Tax Agency addressed a case involving a trust where the Settlor reserved the power to revoke and replace…
Allens Insights
Is change to a stapled structure as good as a tax hol
By Allens
The Federal Court says 'yes', but also 'no' 15 min read In the second case to consider the general anti-avoidance rule contained in Part IVA since it was amended in 2013,…