Jack Cummings presented "Economic Substance - Understanding the Limits; Anticipated Effects of Codification; Partnership, Anti-Abuse Rules, Tax Shelters, Recent Tax Shelter Cases, Ethical Considerations - Distinguishing Good Tax Planning from Aggressive Tax Advice and Criminal Tax Evasion" on May 14, 8:30am - 10:00am, during this conference hosted by the Practising Law Institute (PLI). Jack's presentation covered the following topics.
- The impact on partnership and other transactions of recent case law, 2004 Jobs Act amendments, and administrative developments relating to economic substance and tax shelters
- Infiltration of the pending codification of the economic substance doctrine
- The application of various regulatory anti-abuse rules
- New regulations on tax preparer standards
- Developing interpretations of the attorney-client privilege and work product doctrine
- Circular 230
This three-day seminar traced the partnership tax rules from the birth of the partnership through its operating life, with emphasis on tax issues and planning strategies and opportunities, and then, since for one reason or another such ventures frequently unwind either before or after satisfying their purpose, focused on exit strategies and tax planning possibilities in unwinding.
May 12-14, 2010
University of Chicago / Gleacher Center / Chicago, IL