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 ...
Material advisors with respect to the transaction are required to disclose the transaction under I.R.C. § 6111 and maintain a list of their advisees under I.R.C. § 6112.
“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.”
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 Νοε 2022 · This item discusses the requirement that captive insurance companies must sufficiently distribute their risks for an arrangement to be considered insurance for federal income tax purposes.
22 Μαΐ 2023 · In an attempt to provide parameters for captive insurance arrangements to be treated as insurance companies for federal income tax purposes, the IRS and Treasury Department have issued a variety of guidance.
The tax portion of the budget reconciliation bill, which was approved by the House Ways and Means Committee on September 15, 2021, proposed significant tax increases on corporations and high-income individuals, both of which would affect the insurance industry (the HW&M Proposal).
