Overview
Roger Jones said new IRS assessment period rules for undisclosed tax shelters place the onus on the taxpayer to disclose participation in a listed transaction to be sure that there isn’t an open-ended limitation period. Cascading issues in an open year could lead to massive amounts of additional tax, interest and penalties owed, Mr. Jones pointed out: “It may lead a lot of thoughtful tax advisers to at least go back and ask the question, ‘Did any of my clients engage in these transactions, and if so, did they take the step at the time to disclose it, or if they didn’t, hadn’t we best get going and get it filed?’”
