I answered this question a while back for an HN member back on the day the article first hit the web. I have a bunch of questions from members that I've answer

I answered this question a while back for an HN member back on the day the article first hit the web. I have a bunch of questions from members that I've answered over the last year that I'm unloading onto my website. I figured its makes more sense economically if I shared my advice openly instead of giving it to individuals specifically. The problem with googling this is that it only tells you the basic premise and fails to tell you the problems and the reality of actually applying these tax models. As someone who's worked on these tax models in the past, I can tell you that its never as picture perfect as they make it sound. These companies are always getting audited even though these plans were drafted, approved and done by the "big 4 accounting firms." It was a running joke that the big 4 plans it and the law firms would defend it. It was like we were self-generating projects for us to work on by creating a new "plan" every other year. The IRS always comes back and audits these clients.