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U.S. Income Tax Law |
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Attorney at Law |
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Innovative Ideas The U.S. government has
aggressively attacked tax shelters on audit, and enacted legislation
and promulgated regulations that require their registration and
disclosure. While innovative transactions risk
eliciting an adverse governmental response, taxpayers who
engage in legitimate business activity should (and inevitably will)
continue to seek out and employ innovative tax-reducing strategies.
The question is w The task of creating new structures requires integrating sophisticated economic analysis and financial accounting expertise with tax advice. Frequently, the process must be staged in order to properly identify and resolve significant issues. In addition, the Sarbanes-Oxley legislation and regulatory limitations on structured finance transactions have imposed numerous procedural impediments. Three areas of innovation in leasing structures that deserve attention, in which Mr. Cozart has rendered advice in recent years, involve leasing partnership, project flip partnership and programmatic like-kind exchange structures. These are discussed in Leasing Partnerships, Project Flip Partnerships and Like-Kind Exchanges. However, this discussion is not intended to give, and may not be relied upon as providing, tax advice. |
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here to draw the line between sound tax planning
and what is too risky because, e.g., of a lack of a substantial
business purpose or supportive Congressional or regulatory intent.