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Sec. 301.6112-1 Requirement to prepare, maintain, and furnish lists with respect to potentially abusive tax shelters. (a) In general. Each organizer and seller, as described in paragraph (c) of this section, of a transaction that is a potentially abusive tax shelter, as described in paragraph (b) of this section, shall prepare
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.
Service (IRS) has determined to be a tax avoidance transaction and identi-fied by notice, regulation, or other form of published guidance as a listed transaction. If a transaction becomes a listed transaction after the date on which registration would otherwise be required under this section, and if the transaction otherwise satisfies the con-
The Secretary may prescribe regulations which provide—. I.R.C. § 6111 (c) (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, I.R.C. § 6111 (c) (2) —.
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.
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-. (1) information identifying and describing the transaction,
