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 ...
1 Σεπ 2020 · As mentioned earlier, the F reorganization strategy has gained popularity within private-equity transactions involving S corporations. The overall transaction plan generally requires the seller(s) of an S corporation target to engage in some pre-transaction restructuring.
1 Φεβ 2022 · Secs. 6111 and 6112 further require any material adviser with respect to a reportable transaction to disclose information about the transaction to the IRS and to maintain a list of persons he or she has advised with respect to it.
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-.
(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.
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, I.R.C. § 6111 (a) (2) —
A transaction is considered to be offered to a taxpayer under conditions of confidentiality if the advisor who is paid the minimum fee places a limitation on disclosure by the taxpayer of the tax treatment or tax structure of the transaction and the limitation on disclosure protects the confidentiality of that advisor's tax strategies.
