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Corporate Tax Shelters

Curbing abusive corporate tax shelters is a priority for the Internal Revenue Service and Treasury Department. Developing a strategy to deal with abusive corporate tax shelters is a major strategic initiative of Large and Mid-Size Business (LMSB).

LMSB's Office of Tax Shelter Analysis (OTSA) is responsible for planning, coordinating, and providing assistance to revenue agents working abusive corporate tax shelter issues. More detailed information about OTSA and abusive corporate tax shelters can be found in the Abusive Corporate Tax Shelters Background Paper , and the Department of the Treasury's White Paper.

Also available is an August 28, 2001 press release announcing an agreement between the Internal Revenue Service and Merrill Lynch resolving issues relating to tax shelter registration penalties as well as a June 27, 2002 press release announcing an agreement with the Internal Revenue Service and PricewaterhouseCoopers LLP to resolve issues relating to tax shelter registration and list maintenance.

The IRS toll-free number to the Tax Shelter Hotline is 1-866-775-7474.

Management Advisory Report: The Strategy for Curbing Abusive Corporate Tax Shelter Growth Shows Promise but Could Be Enhanced by Performance Measures

Treasury Acting Assistant Secretary for Tax Policy's Testimony before the Senate Finance Committee on Corporate Tax Shelters

Tax Shelter Notices

Notice 2001-51                  Listed Transactions Update
Notice 2002-21                  Part III - Administrative, Procedural, and Miscellaneous
                                       Tax Avoidance Using Inflated Basis
Rev. Rul. 2000-12              Treatment of certain debt acquisitions
Notice 99-59, page 761      Tax avoidance using distributions of encumbered
                                        property
Notice 2000-15, page 826   Listed transactions
Notice 2000-44, page 255   Tax avoidance using artificially high basis
Notice 2000-60, page 568   Stock compensation corporate tax shelter
Notice 2000-61, page 569
Notice 2001-16, page 730   Intermediary transactions tax shelter
Notice 2001-17, page 730   Contingent liability tax shelter
Notice 2001-45, page 129   Basis shifting tax shelter
Rev. Rul. 99-14, page 3     Business expenses; interest; lease-in/lease-out
                                        transactions