Sheppard on Corporate Planning and Tax Shelters

Lee A. Sheppard (Contributing Editor, Tax Analysts) has published Corporate Planning and Tax Shelters, 109 Tax Notes 165 (Oct. 10, 2005), also available on the Tax Analysts web site as Doc 2005-20445, 2005 TNT 195-7.  Here is part of the Introduction:

Some proactive tax practitioners feel that the rules are being unfairly changed in the middle of the game. The object of their complaints is the revamped Circular 230, which has teeth supplied by the American Jobs Creation Act of 2004 (P.L. 108-357). Some prominent practitioners gathered at the Practising Law Institute (PLI) seminar on tax aspects of mergers and acquisitions on September 30 to complain that their practices should not be subject to the full force of the revamped Circular 230.