Sohodojo Advisory Board Member
Jim Schneider
The Taxman86 Speaks...
24 March 2001
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What Lawyers Can Do About Corporate Tax Shelters; Make a Deal and Make a Difference; and When Quicken Speaks everyone listens.
1. A Tax Guru Speaks And We All Should Listen.
Recently Adjunct Professor of Law [USD and NYU] M. Carr Ferguson [Law Firm Bio-- Mr. Ferguson is the senior partner in Davis Polk & Wardwell's Tax Department and heads the Tax Controversy Practice Group. In addition to tax controversies, his practice includes federal and international taxation of corporation and individuals, principally in the areas of business transactions, including sales, acquisitions, financing, and insolvency arrangements] spoke to the San Diego Bar Association on the subject of Corporate Tax Shelters and what lawyers can do about them. He suggested we ought to look at them through the eyes of the IRS and the Department of Justice for which he headed between 1979 to 1981. He also suggested that we are lawyer's first and tax specialists second. We also suggest that we look at these tax savings program through the eyes of a Tax Court Judge and then you understand why they are not working out very well.
If the Tax Court Speaks in your favor then that is a real plus, if a Court of Appeals Speaks that is even better, and if the IRS publicly concedes then you have a winner until Congress tells us differently. We suggest that working at home, the hottest topic in the New Economy, aka, going wireless, see House of Business, The Magazine For Tomorrow's Broadband Home April 2001, is just such a result. Yourself-Inc.Com, Incorporated has such a discussion on IRC Section 119.
2. Make A Deal And Make A Difference Is The Topic Of The Day.
The Los Angeles Chapter of the Urban Law Institute held a half-day seminar on making development deals in distressed neighborhoods, which apparently includes downtown Los Angeles. The conference and speakers can be found here.
The 03/26/01 Issue of the Downtown Los Angeles covered that even.
Do you see the mention of the Los Angeles Federal Empowerment Zone, the Central City, or Eastside State Enterprise Zones, a tax lawyer or accountant on the panel? Does anyone care about ZERO Capital Gains, Tax Exempt Financing, 39% Investment Credits, State or Federal Hiring Credits, we think so; but the ULI apparently thinks differently. Or, how about the "The Neon Lights of Broadway" By Kathryn MaeseTheater, Entertainment District on Fast Track.
San Diego's Gaslamp Quarter Historic District, which we have been interested in for over 20 years is now fighting to get an Empowerment Zone just as downtown Los Angeles has and many community leaders plus San Diego's Business Journal the Daily Transcript has run a lead article in support thereof. Has the Los Angeles Times which is within the Los Angeles Empowerment Zone said anything about H.R. 5662 "The Community Renewal Tax Relief Act of 2000"? Neither has the Los Angeles Downtown News or the ULI Panel or the Downtown Task Force, both of which has land use/planning lawyers from prominent law firms with strong real estate and business tax departments
3. Quicken Covers The "Community Renewal Tax Relief Act of 2000": [the "Act"]
We suggest you check out Quicken's analysis of the Act It is very good! Now all we have to do is to get them from North County to the San Diego Empowerment Zone, proposed.
Jim Schneider, LL.M.
Taxman86
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The Taxman86 Speaks... is copyright 1998-2010 by James E. Schneider, LL.M. Inc.
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