Αποτελέσματα Αναζήτησης
Highlights of Final Section 6011 Regulations: New reportable transaction category for “transactions of interest” (TOI) which is a transaction that IRS and Treasury believe has a potential for tax avoidance, but for which they lack enough information to determine whether the transaction should be identified specifically as a tax avoidance ...
“The amendment made by this section [amending this section] shall apply to any tax shelter (within the meaning of section 6111 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] as amended by this section) interests in which are first offered for sale after December 31, 1986.”
steps carried out as part of a plan. (1) Transaction that is a section 6111 tax shelter. A section 6111 tax shelter is any transaction that is required to be registered with the IRS under section 6111, regardless of whether that tax shelter is properly registered pursuant to section 6111.
For a protective disclosure to be effective, the advisor must comply with the regulations under this section and § 301.6112-1 by providing to the IRS all information requested by the IRS under these sections.
1 Φεβ 2022 · REPORTABLE TRANSACTIONS. Regs. Sec. 1. 6011 - 4 provides that taxpayers who are required to file a tax return and that participate in a "reportable transaction" for any tax year must disclose information about the transaction to the IRS in a manner and time specified in the regulations.
The rules in section 6111 (a) and (e) and § 301.6111-1T (Q&A-34 through Q&A-39) determine who is required to register a confidential corporate tax shelter.
§301.6111–2 Confidential corporate tax shelters. (a) 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). (2) A confidential corporate tax shel-ter is any transaction— (i) A significant purpose of the struc-
