Tax Shelter Issues and Issue Owners

Abusive Charitable Remainder Trusts - §1.643(a)-8

• SB/SE

Abusive Trust Arrangements Utilizing Cash Value Life Insurance Policies Purportedly to Provide Welfare Benefits - Notice 2007-83

• SB/SE

ASA Investering Partnership v. Commissioner

• LB&I Counsel

§§ 302/318 Basis Shifting - Notice 2001-45

• Issue Owner Executive Sergio Arellano, Director, RFPH

§461(f) Contested Liabilities -  Notice 2003-77

• Issue Owner Executive Keith Jones, Director, NRC

Certain Accelerated Deductions for Contributions to a Qualified Cash or Deferred Arrangement or Matching Contributions to a Defined Contribution Plan -  Revenue Ruling 90-105

• Issue Owner Executive Sunita Lough, Acting Deputy Director, PFTG

Collectively Bargained Welfare Benefit Funds - Notice 2003-24

• SB/SE

Common Trust Fund Straddles - Notice 2003-54

• Issue Owner Executive Steve Whiteaker, DFO East, HMT

Contingent Liabilities - Notice 2001-17 - IRC §351

• Issue Owner Executive Keith Jones, Director, NRC

Contributions to Roth IRA - Notice 2004-8

• SB/SE

Corporate Distributions of Encumbered Property (BOSS)  Notice 99-59

• Issue Owner Executives Cheryl Claybough, Director, PFTG

Custom Adjustable Rate Debt (CARD) - Notice 2002-21 

• Issue Owner Executive Keith Jones, Director, NRC

Debt Straddles - Revenue Ruling 2000-12

• Issue Owner Executives Cheryl Claybough, Director, PFTG

Distressed Asset Debt - Trust Variation (DAD Trust) – Notice 2008-34

• Issue Owner Executive - Steve Whiteaker, DFO East, HMT

Foreign Tax Credit Intermediary - Notice 2004-20 - Foreign Tax Credit TA

• Issue Owner Executive - Lori L. Nichols, Director, International Compliance, Strategy and Policy

Guam Trust - Notice 2000-61

• Issue Owner Executives Cheryl Claybough, Director, PFTG

Intercompany Financing Using Guaranteed Payments -  Notice 2004-31

• Issue Owner Executives Cheryl Claybough, Director, PFTG

Intermediary Transactions - Notice 2001-16

• Issue Owner Executive Patricia Chaback, Director, CTM

Lease-In/Lease-Out or LILO - Revenue Ruling 2002-69

• Issue Owner Executive Walter Harris, Director, FinSvc

Lease Strips/Inflated Basis - Notice 2003-55

• Issue Owner Executive Patricia Chaback, Director, CTM 

Loss Importation Transactions - Notice 2007-57

• Issue Owner Executive - Rosemary Sereti, Acting DFO Manhattan, FinSvc

Major/Minor Tax Avoidance Using Offsetting Foreign Currency Option Contracts - Notice 2003-81

• Issue Owner Executive Patricia Chaback, Director, CTM 

Notional Principal Contracts (NPC) - Notice 2002-35

• Issue Owner Executive Patricia Chaback, Director, CTM

Offshore Deferred Compensation Arrangements - Notice 2003-22

• SB/SE

Partnership Straddle - Notice 2002-50

• Issue Owner Executive Steve Whiteaker, DFO East, HMT

Pass-Through Entity Straddle - Notice 2002-65

• Issue Owner Executive Steve Whiteaker, DFO East, HMT

Pension Plans Involving Insurance Policies with Excess Benefits - Revenue Ruling 2004-20

• TE/GE

Prohibited Allocations of Employer Securities in an S Corporation (ESOP) - Revenue Ruling 2003-6

• TE/GE

S Corporations ESOP - Revenue Ruling 2004-4

• TE/GE

S Corporation Tax Shelter -  Notice 2004-30

• Issue Owner Executive Keith Jones, Director NRC

Sale-In/Lease-Out or SILO Transactions -  Notice 2005-13

• Issue Owner Executive Walter Harris, Director, FinSvc

Son of BOSS - Notice 2000-44

• Issue Owner Executive Sergio Arellano, Director, RFPH

Step Down Preferred/Fast Pay Stock §1.7701(1)-3

• Issue Owner Executives Cheryl Claybough, Director, PFTG

Stock Compensation Transactions -  Notice 2000-60

• Issue Owner Executives Cheryl Claybough, Director, PFTG

Transfers of Compensatory Stock Options to Related Persons - Notice 2003-47 

• Issue Owner Executive Walter Harris, Director, FinSvc

Voluntary Employee Beneficiary Association - Notice 95-34

• SB/SE