The proliferation of corporate tax shelters presents an unacceptable and growing level of tax avoidance behavior. Over the past several years, Congress and the Administration repeatedly have provided targeted responses to specific shelters as they have come to light. The Administration believes that a generic solution to curb the growth of corporate tax shelters must be fashioned, as opposed to the current after-the-fact, ad hoc approach. This, admittedly, is not an easy task. Unlike the individual tax shelters of the 1970s and 1980s, corporate tax shelters may take several forms and do not rely on any single Code section or regulation. For this reason, they are hard to define. Nonetheless, the Administration in its Fiscal Year 2000 Budget proposed several generic remedies, focused on certain identified common characteristics, to curb the growth of corporate tax shelters. As Deputy Secretary Lawrence Summers recently stated, the Administration's proposals are intended ...