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Days Numbered for Those Using 'Son of Boss' Shelter

As part of its continued assault on tax shelters, the IRS has targeted “Son of Boss.” If you’ve participated in the illegal tax shelter, you have until June 22 to come clean and settle your tax debt.

By Stanley H. Block

If you’ve employed an illegal tax shelter or offshore trust to hide money from the federal government, you should be scared.

That is, if you’ve been reading the newspapers.

During the past six months, the IRS has employed some of the most aggressive tactics in its history to take on abusive tax shelters and the cheats who employ them. In fact, in early May, the tax-collecting agency announced its newest target: a tax shelter known as “Son of Boss.”

Marketed in the late ’90s and 2000 to companies and high-income individuals, the Son of Boss tax shelter was later ruled illegal by the federal government. The abusive transactions, however, have continued.

That’s why the IRS took the unusual step of specifying a June 21 deadline to come forward, provide information about your Son of Boss tax shelter, and settle up with the IRS. Otherwise, you could face jail time.

“These transactions were developed and marketed by an interlocking network of commercial interests, including leading law firms, accounting firms and investment banks,” said IRS Commissioner Mark W. Everson in a statement. “Son of Boss deals had only one purpose — the elimination of tax. We encourage investors in these transactions to settle these disputes now to avoid more severe consequences later.”

The IRS estimates that Son of Boss tax shelters have resulted in between $10 million and $50 million in tax loss.

Under the terms of the federal government’s settlement offer, Son of Boss users must pay 100 percent of the back taxes owed, plus interest and penalties. Once the June 22 deadline passes, the federal government will aggressively prosecute offenders.

“Taxpayers should not expect to settle court cases on terms more favorable than those offered in the IRS settlement initiative,” said IRS Chief Counsel Donald Korb. “The IRS will work closely with the Justice Department on Son of Boss cases.”

This is the second high-profile settlement offer the IRS has provided to taxpayers. Last year, the agency offered amnesty to tax cheats who used offshore bank accounts linked to credit cards they used in the United States. The amnesty program resulted in more than 1,200 tax cheats coming forward.

Now with Son of Boss shelters targeted, it could be your turn to come forward. Now is the time to consult a qualified tax professional to get the best possible deal and to ensure that your next vacation stop isn’t in a prison.

Or you can take your chances.

“Anyone who doesn’t come forward can still take the IRS to court,” Everson explained. “In such an instance, the government will vigorously pursue the full tax due, applicable interest and the maximum penalty.”


Stanley H. Block is a Maryland State Tax Attorney and a member of the American Society of IRS Problem Solvers. You can contact him at 410-727-6006 to obtain a free subscription to his newsletter titled The IRS Times & Inquirer.

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