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) 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. (2) Transaction that has a potential for tax avoidance or evasion-- (i) In general. [[Page 138]]
§ 1.6012-1 Individuals required to make returns of income. (a) Individual citizen or resident — (1) In general.
(1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements, (2)
Section 1. Purpose. This revenue procedure provides guidance relating to the obligation of material advisors to prepare and maintain lists with respect to reportable transactions under § 6112 of the Internal Revenue Code.
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.
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.
