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Abusive Tax Shelters

Listed Transactions

LISTED TRANSACTION #1 (Unearned Deductions)
Backdating Plan Contributions Attributable to
Compensation Earned After Year's End

LISTED TRANSACTION #2 (Abusive Welfare Benefit Plans)
Certain Trusts Purporting to be Multiple Employer
Welfare Benefit Funds Exempt from Limits
Under IRC Section 419/419A

LISTED TRANSACTION #3 (ASA Investerings)
Abusive Uses of Partnerships in Transactions
Substantially Similar to the Transactions at Issue in
ASA Investerings Partnership v. IRS
ACM Partnership v. IRS

LISTED TRANSACTION #4 (Abusive Short-Term CRUT & CRATs)
Short-term Charitable Remainder Trusts

LISTED TRANSACTION #5 (BOSS)
"BOSS" (Bond-and-Option Sales Strategy)

LISTED TRANSACTION (Fast-Pay Stock Arrangements)
Treas. Regs. Section 1.7701(l)-3

LISTED TRANSACTION #7 (Bull & Bear Note Transactions)
Bull & Bear Note Transactions
IRS Rev. Ruling 2000-12

LISTED TRANSACTION #8 (SON OF BOSS)
(Uses of Artificially Inflated Basis in the Partnership Setting)
Notice 2000-44

LISTED TRANSACTION #9 (Abusive Uses of Subs. 1.83-6)
Improper Use of a Subsidiary to Satisfy Parent's
Stock-Based Compensation Obligations
IRS Notice 2000-60

LISTED TRANSACTION #10
"Guam Trust Strategies"
IRS Notice 2000-61

LISTED TRANSACTION #11 (MIDCO Deals)
(Agency & Intermediary Corp. Abuses)
IRS Notice 2001-16

LISTED TRANSACTION #12 (Abusive 351 Transfers)
(Using Contingent, Unmatured Liabilities)
IRS Notice 2001-17

LISTED TRANSACTION #13 (Abusive Basis-Shifting)
Foreign Leverage Investment Portfolio (FLIP)
Offshore Portfolio Investment Strategy (OPIS)
IRS Notice 2001-45

LISTED TRANSACTION #14 (CARDS-LOAN ASSUMPTION)
Abusive Basis-Shifting Devices
Using Loan Assumption Agreements
IRS Notice 2002-21

LISTED TRANSACTION #15 (Abusive Notional Principal Contract)
Abusive Uses of a Notional Principal Contract to Create
Timing and Character Whipsaws Against the IRS
IRS Notice 2002-35

LISTED TRANSACTION #16 (Abusive Straddles)s
IRS Notice 2002-50 (Partnership Straddles)
IRS Notice 2002-65 (Pass-Through Entity Straddles)
IRS Notice 2003-54 (Common Trust Fund Straddles)

LISTED TRANSACTION #17 (LILO)
LEASE-IN/LEASE OUT ("LILO") TRANSACTIONS
IRS Rev. Ruling 2002-69

LISTED TRANSACTION #18 (PORCs)
Abusive Producer Owned Reinsurance Companies
IRS Notice 2002-70

LISTED TRANSACTION #19 (Abusive Use of ESOP/S)
Abusive Use of ESOP/S Corp. Arrangements to
Avoid Anti-Abuse Section 409(p) Effective Date
IRS Rev. Ruling 2003-6

LISTED TRANSACTION #20 (Employee Leasing Arrangements)
Abusive Offshore Employee Leasing Arrangements
IRS Notice 2003-22

LISTED TRANSACTION #21 (Abusive Collectively-Bargained Funds)
Abusive Collectively-Bargained Welfare Benefit Funds
Exempted from IRC Section 419/419A Limits
IRS Notice 2003-24

LISTED TRANSACTION #22 (Abusive Sales of Options to FLPs)
Abusive Option Sales to FLPs/Related Parties
IRS Notice 2003-47

LISTED TRANSACTION #23 (LEASE-STRIPPING)
LEASE-STRIPPING
IRS Notice 2003-55

LISTED TRANSACTION #24 ("CLAS")
"Contested Liability Acceleration Strategies"
IRS Notice 2003-77

LISTED TRANSACTION #25 (Foreign Currency Option Contract)
Abusive Offsetting Foreign Currency Option Contract Transactions
IRS Notice 2003-81

LISTED TRANSACTION #26 (Roth IRA)
Abusive Roth IRA Transactions
IRS Notice 2004-8

LISTED TRANSACTION #27 (Abusive Use of ESOP/S Corp. Ownership)
Arrangements Aimed at Bypassing Synthetic Equity Rules
IRS Rev. Ruling 2004-4

LISTED TRANSACTION #28 (Abusive 412(i) Plans)
Abusive Section 412(i) Plans with Excessive Life Insurance
IRS Rev. Ruling 2004-20

LISTED TRANSACTION #29 (Abusive Foreign Tax Credit Transaction..)
Abusive Foreign Tax Credit Transactions
IRS Notice 2004-20

ISTED TRANSACTION #30 (Abusive S Corporation Income Shifting..)
Abusive S Corporation Income Shifting Arrangements (SC2)
IRS Notice 2004-30

LISTED TRANSACTION #31 (Abusive Partnership Intercompany..)
Abusive Partnership Intercompany Financings
IRS Notice 2004-31

Tufts Law Firm
Tufts Law Firm, PLLC
159 Lookout Place, # 202  •  Maitland, Florida 32751
Phone: (407) 647-8886  •  Fax: (407) 641-8082
Toll Free: 1-866-747-3423

Disclaimer
Content is general information only. Information is not provided as advice for a specific matter, nor does its
publication create an attorney-client relationship. For legal advice on a specific matter, consult an attorney.

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