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IRS Weapons Against Aggressive Tax Planning

February 19, 2019, Trusts & Trustees

Michael Pfeifer and Sae Jin Yoon -- members of Caplin & Drysdale's Private Client Group -- authored the article "IRS Weapons Against Aggressive Tax Planning" for the February 2019 issue of Trusts & Trustees.  Below is an abstract of the article, and please view the PDF link above to access the full article.

The long-standing principle that taxpayers are generally free to creatively engage in tax planning is not without limits. In fact, with the creation of increasingly sophisticated and complex tax planning structures by taxpayers and tax practitioners, there has been pushback with equally strong force from tax enforcement authorities and the courts against tax planning that goes a step too far. This article explores the ethical obligations of tax professionals advising clients without overstepping the boundaries of legitimate tax planning, as well as judicial doctrines frequently employed by the Internal Revenue Service and the US courts to keep aggressive taxpayers in check.

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