id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-9798	Noked, Noam; Marcone, Zachary; Tsang , Alison	THE EXPANSION AND INTERNATIONALIZATION OF MANDATORY DISCLOSURE RULES	2022	42	.pdf	application/pdf	23666	957	48	MANDATORY DISCLOSURE RULES 135 which their income tax liability is affected by the transaction.87 Reportable transactions would include transactions identified by the IRS in published guidance as tax avoidance transactions, i.e.,.,., listed transactions and transactions exceeding certain monetary thresholds which had certain hallmarks commonly associated with corporate tax shelters.88 From August 2000 to October 2002, the temporary rules underwent four rounds of revision, during which time the disclosure requirement was extended to non-corporate taxpayers including individuals, trusts and partnerships.89 These amendments were made because “potentially abusive tax avoidance transactions are increasingly being used by high net-worth individuals” and that “both corporations and individuals often employ partnerships and trusts to achieve unintended tax results.”90 MANDATORY DISCLOSURE RULES 155 tax evasion, and tax avoidance transactions, which have been the primary focus of MDRs since their inception.238 Overall, these changes could be described as a shift away from a rule-based approach, which tries to identify and address specific weaknesses in the tax system (initially by using formulas to determine which tax schemes are reportable), toward a standard-based, anti-avoidance approach.239 This standard-based approach is reflected in the extensive use of generic hallmarks and the incorporation of the main benefit test in newer MDRs.240 The CRS MDRs, for example, make direct references to the intended policy of CRS when determining what arrangements must be reported.241 Thus, MDRs are becoming broad anti-avoidance standards and are imposing reporting obligations on a wide variety of transactions that violate the intent of tax laws.	cache/taxlaw-9798.pdf	txt/taxlaw-9798.txt