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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 ...
- [Code of Federal Regulations] [Title 26, Volume 18]
(a) In general.--(1) Under section 6111(d) and this section,...
- [Code of Federal Regulations] [Title 26, Volume 18]
Section. 26 U.S. Code § 6111 - Disclosure of reportable transactions. U.S. Code. Notes. prev | next. (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, (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.
4 Μαρ 2003 · proposed regulations regarding sections 6011, 6111, and 6112 (TD 8877, REG-103735-00; TD 8876, REG-110311-98; TD 8875, REG- 103736-00) (the February 2000 regulations).
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) —.
(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).
§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,
