Potentially Abusive Sheltering in the High Profile Tax Industry: KPMG, LLP an Illustrative Case Study
Schiebout, Kyle Gene
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The concept of tax sheltering is becoming increasingly attractive to clients, ambiguous to tax practitioners, and detrimental to the United States taxation system, which creates urgency for taxpayers, practitioners, and governmental officials to become educated on the industry's latest, most complex, and controversial generation of tax products. Thus, the purpose of this research is to provide a summarization of the abusive sheltering environment, its products, and players, during the past ten years. While maintaining a focus on the most crucial level of tax sheltering, taxpayers with $10 million plus in tax liability, this thesis establishes a background of the sheltering industry, outlines potentially abusive components of high profile shelters, discusses the outcome of abusive sheltering from both government and practitioner points of view, and lastly reviews relevant ethical concerns of the issue. The research methodology is qualitative in nature and obtains the most relevant information, which is typically found in governmental reports and congressional testimony, to form a concise industry report. Research has concluded that a handful of CPA's among the most prominent accounting firms in the world were previously involved with creating, soliciting, and implementing abusive tax shelters.