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Tag: Henry Stow Lovejoy

Henry Stow Lovejoy Participates In A Webinar Entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” For Strafford Publications

On August 3, 2021, Henry Stow Lovejoy participates in a webinar entitled “Mastering Form 5472: Filing Requirements for Foreign Individuals, LLCs, and Companies” for Strafford Publications. Course Description: Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign Corporation Engaged in a U.S. Trade or Business, is

Yoram Keinan And Stow Lovejoy Participate In The Panel Titled “The Current State Of The Economic Substance Doctrine And Its Effect On Financial Institutions” At The ABA Section Of Taxation, May Tax Meeting

The economic substance doctrine was “codified” in 2010, effective for transactions after March 31, 2010, and a new strict liability penalty added for economic substance understatements.  While the IRS and Treasury provided initial guidance on the application of the codified doctrine and the penalty, only a handful of cases have

When Should A Taxpayer Know That A Tax Shelter Is Too Good To Be True?

By Bryan C. Skarlatos & Henry Stow Lovejoy Journal of Tax Practice & Procedure June – July 2017 Edition Taxpayers who have underpaid their taxes can avoid accuracy-related penalties under Code Sec. 6662 by demonstrating that they acted with reasonable cause and in good faith. In general, the most important factor in determining