Αποτελέσματα Αναζήτησης
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 ...
PART 1—INCOME TAXES tax returns or statements § 1.6011-4 Requirement of statement disclosing participation in certain transactions by taxpayers. (a) In general. Every taxpayer that has participated, as described in paragraph (c)(3) of this section, in a reportable transaction within the meaning of paragraph (b) of this
alization of tax benefits from the transaction. All the facts and circumstances relating to the transaction will be considered when de-termining whether a fee is refundable or contingent, including the right to reimbursements of amounts that the parties to the transaction have not des-ignated as fees or any agreement to p.
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
In general. (1) Under section 6111(d) and this section, a confidential corporate tax shelter is treated as a tax shelter subject to the requirements of sections 6111 (a) and (b).
20 Σεπ 2024 · Section 6111 - Disclosure of reportable transactions. (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- (1) information identifying and describing the transaction,
A material advisor required to file a disclosure statement under this section must file a completed Form 8918, “Material Advisor Disclosure Statement” (or successor form) in accordance with this paragraph (d) and the instructions to the form.
