The Tax Law RoundUp blog reviews three recent IRS victories in tax shelter cases. The first case, Southgate Master Fund LLC v. United States, involves foreign built-in tax losses. The second case, Pritired 1 LLC, et al v. United States, involves foreign tax credits. The third case, WFC Holdings Corp. v. United States, involves generating losses from underwater commercial leases.
See Steven Schneider, "IRS Has Three New Wins On Tax Shelter Cases," Tax Law RoundUp (October 5, 2011).
Posted by Derek Young, Associate Editor, Wealth Strategies Journal

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