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  1. To be considered complete, the form must describe the expected tax treatment and all potential tax benefits expected to result from the transaction, describe any tax result protection with respect to the transaction, and identify and describe the transaction in sufficient detail for the IRS to understand the tax structure of the reportable ...

  2. Except as provided in paragraph (2), the amendments made by this section [amending this section and sections 6662 and 6707 of this title] shall apply to any tax shelter (as defined in section 6111(d) of the Internal Revenue Code of 1986, as amended by this section) interests in which are offered to potential participants after the Secretary of ...

  3. Subtitle F. Chapter 61. Subchapter B. § 6111. Sec. 6111. Disclosure Of Reportable Transactions. I.R.C. § 6111 (a) In General — Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth— I.R.C. § 6111 (a) (1) —

  4. 4 Μαρ 2003 · section 6011 and section 6111, that a privilege held by the taxpayer does not cause a transaction to be confidential. The IRS and Treasury Department believe that this clarification is not necessary because the attorney-client privilege (or the confidentiality privilege of section 7525(a)) does not affect whether a transaction is confidential.

  5. provided on the form must describe the expected tax treatment and all potential tax benefits expected to result from the transaction, describe any tax result protection (as defined in Treas. Reg. § 301.6111-3(c)(12)) with respect to the transaction, and identify and describe the transaction in sufficient detail for the

  6. 1 Φεβ 2022 · Under Regs. Sec. 1. 6011-4 (d), a taxpayer discloses a reportable transaction by attaching Form 8886, Reportable Transaction Disclosure Statement, to the tax return. To be considered complete, the information provided on Form 8886 must: Describe the expected tax treatment and all potential tax benefits expected to result from the transaction;

  7. To be considered complete, the information provided on the form must describe the expected tax treatment and all potential tax benefits expected to result from the transaction, describe any tax result protection with respect to the transaction, and identify and describe the transaction in sufficient detail for the IRS to be able to understand ...

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