The ABA Tax Section offers a teleconference and webcast today on The New Tax Shelter Disclosure Rules: What You Need to Know Now from 1:00 – 2:30 p.m. EST:

On November 1, 2006, the Treasury Department and the IRS issued proposed amendments to the tax shelter disclosure regulations for taxpayers and material advisors. The current regulations were issued prior to the American Jobs Creation Act of 2004, which imposed significant new penalties on taxpayers and advisors who fail to disclose reportable transactions. The Act also created a new accuracy-related penalty for many reportable transactions, along with more stringent penalty defense rules.

Although the proposed tax shelter disclosure regulations retain the basic structure and rules of the existing regulations, the Treasury and the IRS are proposing a number of important changes, including the creation of a new "transactions of interest" category of reportable transactions. Other changes include the targeting of tax result insurance; the elimination of the lease transaction exception; the announcement of a new disclosure form for material advisors; and the clarification of the list-maintenance rules for material advisors. Our distinguished government panelists had primary responsibility for these new regulations. They will discuss these changes and what they mean for taxpayers and their advisors.

Faculty:

• Julian Kim (Latham & Watkins, Washington, D.C.)
• William P. O’Shea (Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel)
• Anita Soucy (Office of Tax Policy, U.S. Treasury Department)
• Donna Marie Young (Special Counsel to Associate Chief Counsel (Passthroughs and Special Industries), IRS Office of Chief Counsel)