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GE just lost an appeal on a big basis-shifting tax shelter, to the point of getting hit with a 20% penalty. While that seems bad, Jack Townsend makes an arresting comparision of GE's consequences from a "BS" shelter attempting to save GE over $60 million with the treatment of foot-faulters being hammered under the IRS pogrom against offshore tax evasion. From Mr. Townsend:
Was GE's conduct in this case any more morally upright or commendable than most of the persons who have been herded into OVDP 2009 and OVDI 2011 with far more draconian penalties? Yet, GE drew a relatively light 20% penalty.
Because you have to shoot the jaywalkers to wrist-tap the bad guys.
Related: Darth Shulman to foreign account holders: I am altering the deal. Pray I don't alter it any further.
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