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The threshold amount of gross income is $50,000 in the case of a reportable transaction where substantially all of the tax benefits are provided to natural persons ($10,000 for listed transactions). For other than natural persons, the threshold amount is $250,000 ($25,000 for listed transactions).
For purposes of determining whether any investment is a tax shelter by reason of section 6111(c)(1)(B)(iii) of such Code (as added by this section), only offers for sale after August 31, 1984, shall be taken into account.
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) — information identifying and describing the transaction,
(f) Designation agreements. If more than one material advisor is required to disclose a reportable transaction under this section, the material advisors may designate by written agreement a single material advisor to disclose the transaction.
1 Φεβ 2022 · The IRS determines whether the ruling request itself satisfies the disclosure requirement (Regs. Sec. 1. 6011-4 (f)(1)). A taxpayer may make a protective disclosure by following the requirements of this rule.
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
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, (2) information describing any potential tax benefits expected to result from the transaction, and.
