Bill > S1373

This bill aims to improve tax administration in the Commonwealth by clarifying the "sham transaction doctrine," which allows the commissioner of revenue to disallow tax benefits from transactions that lack a genuine business purpose or economic substance beyond tax avoidance, though it exempts common business choices like debt vs. equity financing or entity selection. It also grants corporations a six-month filing extension, extended to seven months for certain taxpayers subject to specific tax provisions, and mandates the commissioner to pay reasonable attorney fees and interest if the appellate tax board rules in favor of a taxpayer whose settlement offer of 35% or more of the assessed liability was rejected. Furthermore, the bill revises installment payment requirements for corporations, generally requiring four equal quarterly payments of their estimated annual tax liability, and establishes a two-month tax amnesty program in fiscal year 2014, waiving penalties and offering reduced interest for taxpayers who come into compliance by June 30, 2014, with exceptions for those under criminal investigation and specific types of taxes.