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 ...
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.
Sec. 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 shelter is any transaction--
“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.”
Internal Revenue Servi. e, Treasury §1.6011–4(2) Existence of DISC. A corporation which is a DISC and which is in exist-ence during any portion of a taxable year is required to make a return for that fractional part of it. istence.[T.D. 7533, 43 FR 6603, Feb. 15, 1978]1.6011–3 Requirement of sta. ement from pa.
27 Μαρ 2017 · The U.S. Department of the Treasury and the Internal Revenue Service issued final regulations effective March 31, 2015 that clarify what steps must be taken to ensure that a taxpayer’s assessment period closes for tax years in which a listed transaction occurred. . Reportable Transaction Regime.
In the July 2007 regulations, the IRS and Treasury Department amended 26 CFR parts 20, 25, 31, 53, 54, and 56 to provide that certain taxpayers would be required to disclose transactions of interest, in addition to listed transactions, on their Federal tax returns under section 6011.
