Abusive Tax Shelter Shutdown and Taxpayer Accountability Act of 2007

To amend the Internal Revenue Code of 1986 to curb tax abuses by disallowing tax benefits claimed to arise from transactions without substantial economic substance, and for other purposes.

5/16/2007--Introduced.
Abusive Tax Shelter Shutdown and Taxpayer Accountability Act of 2007 - Amends the Internal Revenue Code to revise or add provisions relating to tax shelter activity, including provisions to:
(1) define "economic substance" for purposes of evaluating tax shelter transactions;
(2) increase penalties for large entities and high net-worth individuals for failure to disclose certain tax shelter transactions;
(3) impose penalties for understatements of tax due to transactions lacking economic substance;
(4) deny material tax advisors a claim of privilege as to the identity of a client;
(5) revise standards for the penalty for understatement of tax liability by income tax return preparers and increase the penalties for such understatements;
(6) revise and increase the penalties for frivolous tax submissions;
(7) deny a tax deduction for interest on underpayments of tax due to nondisclosed reportable transactions and transactions lacking economic substance;
(8) expand the authority of the Secretary of the Treasury to disallow certain tax benefits arising from the acquisition of corporate stock;
(9) modify certain passive loss rules for controlled foreign corporations; and
(10) provide a rule for the reduction in basis of corporate stock for which certain extraordinary dividends are received.


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Sponsor

• Rep. Lloyd Doggett [D, TX-25]
• and 52 Co-Sponsors
  • Rep. Robert Andrews [D, NJ-1]
  • Rep. Xavier Becerra [D, CA-31]
  • Rep. Howard Berman [D, CA-28]
  • Rep. Julia Carson [D, IN-7]
  • Rep. Emanuel Cleaver [D, MO-5]
  • Rep. John Conyers [D, MI-14]
  • Rep. Elijah Cummings [D, MD-7]
  • Rep. Danny Davis [D, IL-7]
  • Rep. Peter DeFazio [D, OR-4]
  • Rep. Rosa DeLauro [D, CT-3]
  • Rep. Keith Ellison [D, MN-5]
  • Rep. Rahm Emanuel [D, IL-5]
  • Rep. Sam Farr [D, CA-17]
  • Rep. Chaka Fattah [D, PA-2]
  • Rep. Bob Filner [D, CA-51]
  • Rep. Barney Frank [D, MA-4]
  • Rep. Raymond Green [D, TX-29]
  • Rep. Raul Grijalva [D, AZ-7]
  • Rep. Phil Hare [D, IL-17]
  • Rep. Maurice Hinchey [D, NY-22]
  • Rep. Sheila Jackson-Lee [D, TX-18]
  • Rep. Eddie Johnson [D, TX-30]
  • Rep. Henry Johnson [D, GA-4]
  • Rep. Marcy Kaptur [D, OH-9]
  • Rep. Dennis Kucinich [D, OH-10]
  • Rep. John Larson [D, CT-1]
  • Rep. Barbara Lee [D, CA-9]
  • Rep. John Lewis [D, GA-5]
  • Rep. Carolyn Maloney [D, NY-14]
  • Rep. Edward Markey [D, MA-7]
  • Rep. James McDermott [D, WA-7]
  • Rep. James McGovern [D, MA-3]
  • Rep. Michael McNulty [D, NY-21]
  • Rep. George Miller [D, CA-7]
  • Rep. Patrick Murphy [D, PA-8]
  • Rep. Jerrold Nadler [D, NY-8]
  • Rep. Grace Napolitano [D, CA-38]
  • Rep. Richard Neal [D, MA-2]
  • Rep. Donald Payne [D, NJ-10]
  • Rep. Bobby Rush [D, IL-1]
  • Rep. Loretta Sanchez [D, CA-47]
  • Rep. Janice Schakowsky [D, IL-9]
  • Rep. Allyson Schwartz [D, PA-13]
  • Rep. Brad Sherman [D, CA-27]
  • Rep. Louise Slaughter [D, NY-28]
  • Rep. Hilda Solis [D, CA-32]
  • Rep. Fortney Stark [D, CA-13]
  • Rep. Betty Sutton [D, OH-13]
  • Rep. John Tierney [D, MA-6]
  • Rep. Christopher Van Hollen [D, MD-8]
  • Rep. Maxine Waters [D, CA-35]
  • Rep. Henry Waxman [D, CA-30]
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Committees

• House Ways and Means

Amendments

This bill has no amendments.

Amendments to H.R.2345

Number	Status	Purpose

Bill Status

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Introduced		Voted on by House		Voted on by Senate		Considered By President		Bill Becomes Law
May 16, 2007

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All Bill Actions

• May 16, 2007: Referred to the House Committee on Ways and Means.
• Introduced on May 16, 2007.

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Related Issue Areas:

• Taxation
• Accounting
• Administrative procedure
• Administrative remedies
• 39 more
• Affiliated corporations
• Business
• Confidential communications
• Corporate finance
• Corporate mergers
• Corporation taxes
• Debt
• Department of the Treasury
• Depreciation and amortization
• Dividends
• Evidence (Law)
• Executive departments
• Finance
• Fines (Penalties)
• Foreign corporations
• Fraud
• Government information
• Government paperwork
• Income tax
• Interest
• Law
• Leases
• Losses
• Profit
• Stockholders
• Stocks
• Subsidiary corporations
• Tax administration
• Tax consultants
• Tax credits
• Tax deductions
• Tax evasion
• Tax liens
• Tax penalties
• Tax preparers
• Tax returns
• Tax shelters
• Taxation of foreign income
• Valuation

Data from the Congressional Research Service

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Blog Coverage

February 26, 2008 Advocacy’s greatest hits

During the interview, we discuss Advocacy’s RFA enforcement work (including this initiative), the Regulatory Flexibility Improvements Act (HR 2345), and that small business research I mentioned, and more. ...

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Source: The Journal Blog

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May 22, 2007 HR 2345, the Abusive Tax Shelter Shutdown and Taxpayer ...

Last week there was an interesting article on Tax Notes Today as to a pending bill pertaining to Economic substance. But just as quickly, ie in a blink of an eye, it was removed. However, this did not stop the...

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Source: Tax Litigation Blog

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May 15, 2007 HR 2345, To amend the Internal Revenue Code of 1986 to curb tax ...

HR 2345 would amend the Internal Revenue Code of 1986 to curb tax abuses by disallowing tax benefits claimed to arise from transactions without substantial economic substance....

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Source: WashingtonWatch.com - Welcome to WashingtonWatc...

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