Tax Planning on the Edge: Potential Penalties in the International Tax Arena

By Bryan C. Skarlatos
Journal of Tax Practice & Procedure
April - May 2014 Edition

Do tax practitioners working in the United States care whether their advice may help to evade tax in a foreign country as long as the advice is legal in the United States? And what about tax practitioners who are devising structures in a foreign country? Do they care whether their structures violate U.S. law as long as they are legal in the foreign country? As the economy becomes more global, these questions arise more frequently and the law is beginning to provide answers.

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