Definitions

Tax Shelter - A tax shelter or abusive tax shelter are the common names for a "tax avoidance transaction."

Tax Avoidance Transaction - A tax avoidance transaction means any plan or arrangement devised for the principal purpose of avoiding federal income tax, and includes but is not limited to, "listed transactions" as defined by the IRS.

Listed transaction - A "listed transaction" is a transaction that is the same as or substantially similar to one that the IRS has determined to be a tax avoidance transaction and identified by IRS notice or other form of published guidance.