Washington, D.C. - The Internal Revenue Service has expanded its lists of "transactions of interest" and "listed transactions" that taxpayers must disclose. Taxpayers who fail to disclose their participation in the transactions may be subject to penalties, as are advisors who fail to disclose or maintain and furnish the information to the IRS.

The new transactions include ones in which a U.S. taxpayer that owns controlled foreign corporations that hold stock of a lower-tier CFC through a dom­estic partnership takes the position that Subpart F income of the lower-tier CFC or an amount determined under Section 956(a) related to holdings of U.S. property by the lower-tier CFC does not result in income inclusions for the U.S. taxpayer.

For more, visit and click on "Abusive Tax Shelters and Transactions."


Arlington, Va. - BNA has acquired the training seminar and conference businesses of the Council for International Tax Education, Atlas Information Group and the Structured Finance Institute.

The three groups are all headquartered in White Plains, N.Y., and provide continuing education programs and networking opportunities for tax, accounting, legal and business professionals. Financial details of the acquisitions were not disclosed.

Since CITE's establishment in 1989, the organization's seminars and conferences have educated U.S. and foreign multinationals and companies engaged in international business on the tax, legal and accounting aspects of doing business overseas. Atlas and SFI events focus on a variety of tax, legal and financial topics, including long-running programs on film and TV finance, captive insurance, and structured financial products.

The acquisitions will be integrated into the BNA Tax & Accounting product and service offerings, and continue the company's move into tax education and training.

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