TAX NEWS - January 2010

Consultants Wanted: California Seeks Experts Knowledgeable in Abusive Tax Shelter Transactions

Abusive Tax Avoidance Transactions (ATAT) cost California billions of dollars each year. In 2004, we collected a record $1.4 billion from taxpayers participating in tax shelters during our Voluntary Compliance Initiative. Currently, we have an inventory of audit cases worth billions that need expertise beyond what we have in-house. As a result, we have decided to seek staff training assistance and help with our investigations from the private sector through the use of contract consulting.

California has worked successfully in the past with outside consultants on some of our most complex ATAT investigations. It is a great way to expand or maintain your practice and assist a governmental agency unwind some interesting, exciting, and exotic tax shelter cases. Currently, we are looking for specialists in the fields of financial instruments, structures, and arrangements that such abusive transactions employ. Additionally, we want experts or specialists who have substantial knowledge and can instruct staff on subject areas relating to ATAT such as:

- Financial Product Experts.
- Economist and Risk Theorists.
- Valuation Appraisers.
- Tax Law Specialists.
- Industry Specialists.
- Regulatory Specialists.

Outside consultants will assist staff on a case-by-case basis, as needed basis, and as the consultant is available. Specific contracts for each job are made from a pool of available experts that have specific expertise in the particular area needed. Assistance may be needed in investigations at any of our California, New York, Chicago, and Houston offices. Our ATAT investigations may include individuals, pass-through entities, corporations, and special purpose entities.

If you are interested in contracting with California to help FTB train staff, investigate taxpayers who may have engaged in these types of transactions, or know someone else who might be interested, please contact us at 916.845.7870 weekdays between 8 a.m. and 5 p.m. PST, excluding holidays, or email: Nellie.Bohling@ftb.ca.gov.