Bad Tax Shelters

There will be no leftovers at the putlucks. Indiana Marijuana Church Granted Tax-Exempt Status, Plans ‘Call To Worship’ When Members Will Light Up (TaxProf).

Jacob L. Todres (St. John's), Bad Tax Shelters -- Accountability or the Lack Thereof: Ten Years of Tax Malpractice, 66 Baylor L. Rev. 602 (2014):

In the 1990’s and early 2000’s the tax landscape in the United States was overrun by an epidemic of tax shelters that was unprecedented. The shelters were designed and sold by seemingly reputable large accounting and law firms. The same shelters were sold to many taxpayers. They became generic, off-the-shelf, products. However, the tax shelters had no business substance. The shelters were eventually found to be invalid by the courts. In light of the invalidity of the shelters, the large fees paid for the shelters and the large damages caused by participating in the invalid shelters, there were predictions that many malpractice suits against the sellers of the shelters would ensue.

Bloomberg:  Wal-Mart Has $76 Billion in Undisclosed Overseas Tax Havens, by Jesse Drucker & Renee Dudley:

Wal-Mart Stores Inc. owns more than $76 billion of assets through a web of units in offshore tax havens around the world, though you wouldn’t know it from reading the giant retailer’s annual report.

A new study has found Wal-Mart has at least 78 offshore subsidiaries and branches, more than 30 created since 2009 and none mentioned in U.S. securities filings. Overseas operations have helped the company cut more than $3.5 billion off its income tax bills in the past six years, its annual reports show.

The Swiss government and hundreds of Swiss banks have been roiled by the U.S. crackdown on American tax evaders. With six years of almost non-stop hits to the country and its bankers, it may be no surprise that now Switzerland is publishing the names of foreign tax evaders. Some observers are calling this the real and final end of Swiss bank privacy tradition, which mostly dates to the 1930s. Deutsche Welle has cited the Swiss media Sonntagszeitung for the news, saying that the Swiss government will list the names, birthdates and nationalities of alleged tax evaders in its federal newspaper.

 Switzerland publishes tax evader list

• Gabriel Zucman (London School of Economics), Taxing Across Borders: Tracking Personal Wealth and Corporate Profits
• Elizabeth Chorvat (Illinois) presents Expectations and Expatriations: A Long-Run Event Study at the Oxford University Centre for Business Taxation today as part of its Research Seminar Series:
  This paper represents the first event study of corporate expatriations since Desai and Hines (2002), and is the first study to link corporate expatriation behavior to intangibles. Utilizing a bootstrap methodology, the paper demonstrates that corporate expatriations – whether naked inversions or redomiciliations in the context of business combinations – generate statistically and economically significant excess returns on the order of 225% above market returns in the years following the inversion.
• News from the Profession. Madoff Auditor Better at Cooperating Than Auditing, Won’t Serve Time (Caleb Newquist, Going Concern)
    
• Jack Townsend, Former House Speaker Indicted for Stucturing and Lying to Federal Agents. It appears blackmail was involved. Robert Wood has more.