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Tax Avoidance

127 published works

  1. Wills, Trusts & Estates Prof Blog

    IRS Final Rules Identify Syndicated Conservation Easements as Abusive Tax Transactions

    By Gerry W. Beyer

    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…

  2. Dollars & Sense

    IRS Further Combats Basket Contract Transactions with Proposed Regs

    By Angela Alloju

    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…

  3. 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…

  4. 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,…

  5. 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…

  6. Beneficially Yours

    FICA Tax Avoidance Wellness Program Viewed Unfavorably by 87,000 New IRS Agents

    By Ben Conley, Diane Dygert

    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…

  7. Canadian Lawyer Mag

    SCC finds company committed abusive tax avoidance in case dealing with general anti-avoidance rule

    By Canadian Lawyer Mag

    Decision deals with Income Tax Act provision restricting when business losses can offset tax burden

  8. 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]…

  9. 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…

  10. 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,…