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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)
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) —.
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.
§ 301.6011-2 Required use of electronic form. (a) Meaning of terms. The following definitions apply for purposes of this section: (1) Magnetic media or electronic form.
§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.
