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(1) Material advisor. (A) In general The term “ material advisor ” means any person— (i) who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and. (ii)
- 26 U.S. Code § 6110 - Public inspection of written determinations
The Internal Revenue Service shall make any Chief Counsel...
- 26 CFR § 301.6111-3 - Disclosure of reportable transactions.
For a protective disclosure to be effective, the advisor...
- 26 U.S. Code § 6110 - Public inspection of written determinations
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 ...
Subchapter B. § 6111. Sec. 6111. Disclosure Of Reportable Transactions. I.R.C. § 6111 (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— I.R.C. § 6111 (a) (1) — information identifying and describing the transaction,
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.
§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,
A tax statement relates to an aspect of a transaction that causes it to be a loss transaction if the statement concerns an item that gives rise to a loss described in Sec. 1.6011- 4(b)(5) of this chapter. (E) Transactions with a significant book-tax difference.
1 Ιαν 2024 · Internal Revenue Code § 6111. Disclosure of reportable transactions. Current as of January 01, 2024 | Updated by FindLaw Staff. (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--