Tax Shelter Update

1
Tax Shelter Update

• Debra Petersen
• California Franchise Tax Board
• May 7, 2007

2
California Tax Shelter Audits

• Taxpayers Individuals, Pass Through Entities,
  Corporations, Trusts
• Open Cases 768 taxpayers with estimated tax
  penalties of 660 million
• Closed Cases 475 taxpayers with estimated tax
  penalties of 317 million
• VCI Cases 753 million final and
  411 million contested

3
Other CA Activities

• ATSU Activities
• Promoter Audits
• Review of Disclosure and Registration Statements
• Off shore Transaction Group
• Chief Counsel Penalty Waivers

4
CA FTB Cases

• Board of Equalization Appeal James A. and Lisa
  E. Alyn, No. 258065 (Son of Boss)
• Litigation Cases
• City National Bank (RIC, REITs, PORCs)
• City National Corporation (REITs)
• Estate of Thomas Gonzales II (Son of Boss)
• Kerry Bratton (Promoter Penalty)

5
Federal Activities

• SPSI Hearing Offshore Tax Shelters
• Proposed Federal Legislation
• Cases
• Federal Indictments Guilty Pleas