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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 ...
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--. In general.
4 Μαρ 2003 · This document amends 26 CFR part 1 to provide rules. relating to the disclosure of reportable transactions by. certain taxpayers on their Federal tax returns under section. 6011, and also amends 26 CFR parts 20, 25, 31, 53, 54, and 56. to provide rules for purposes of estate, gift, employment, and.
§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-
for the regulations governing practice before the IRS. (5) Loss transactions—(i) In general. A loss transaction is any transaction re-sulting in the taxpayer claiming a loss under section 165 of at least— (A) $10 million in any single taxable year or $20 million in any combination of taxable years for corporations;
14 Νοε 2011 · This document contains final regulations that provide rules relating to the disclosure of listed transactions and transactions of interest with respect to the generation-skipping transfer tax under section 6011 of the Internal Revenue Code (Code), conforming amendments under sections 6111 and 6112, and rules relating to the preparation and ...
The Secretary may prescribe regulations which provide— (1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would other-wise be required to meet such requirements, (2) exemptions from the requirements of this section, and (3) such rules as may be necessary or appro-