October 15, 2002
Tax partner Richard L. Reinhold was interviewed for an article in the October 7th edition of the Bureau of National Affairs' Lead Tax Report on the government’s decision to enter into agreements with taxpayers involved in three types of tax shelter transactions.
Tax partner Richard L. Reinhold was interviewed for an article in the October 7th edition of the Bureau of National Affair’s Lead Tax Report on the government’s decision to enter into agreements with taxpayers involved in three types of tax shelter transactions. The article, entitled “IRS and Treasury Offer, for Limited Period, To Settle Three Tax Shelter Transactions,” looks at the Internal Revenue Service’s and Treasury Department’s recently announced “shelter resolution initiative,” applying to corporate-owned life insurance (COLI) cases, Section 302/318 basic-shifting transactions and Section 351 contingent liability transactions. Mr. Reinhold told the BNA that the settlement offers for the stock basis transactions represented “a statesmanlike solution to a very vexing set of problems for the government,” and that many taxpayers may choose to settle. He also explained that because the transactions involving stock basis adjustments “have some technical support in the law,” it was reasonable for the IRS to attempt to settle these cases. Richard Reinhold is a partner in Willkie’s Tax Department in New York, specializing in domestic and international business tax matters relative to mergers and acquisitions, joint ventures, new financial products, corporate restructurings, and financing transactions.