It seems like the IRS is attacking tax shelters on all fronts. First you saw the IRS go after a number of the Big Four and this past week you saw the Service issue rulings and regulations curtailing abusive tax shelters involving the claiming of the foreign tax credit and 412(l) plans funded with specially designed life insurance.
The IRS is starting to react faster than in the past. I see it as a kind of let's try and nip it in the bud, rather than waiting to fight it out in the courts for a favorable decision.
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