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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 ...
Except as provided in paragraph (2), the amendments made by this section [amending this section and sections 6662 and 6707 of this title] shall apply to any tax shelter (as defined in section 6111(d) of the Internal Revenue Code of 1986, as amended by this section) interests in which are offered to potential participants after the Secretary of ...
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) —
4 Μαρ 2003 · 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
1 Φεβ 2022 · Under Regs. Sec. 1. 6011-4 (d), a taxpayer discloses a reportable transaction by attaching Form 8886, Reportable Transaction Disclosure Statement, to the tax return. To be considered complete, the information provided on Form 8886 must:
Section 301.6111-3(a) provides that each material advisor, as defined in Treas. Reg. § 301.6111-3(b), with respect to any reportable transaction, as defined in Treas. Reg. § 1.6011-4(b), must file a return, as described in Treas. Reg. § 301.6111-3(d) by the date described in Treas. Reg. § 301.6111-3(e). Treas. Reg. § 301.6111-3(a).
This document contains final regulations that amend 26 CFR part 26 to provide rules for purposes of the generation-skipping transfer tax that require the disclosure of listed transactions and transactions of interest by certain taxpayers on their Federal tax returns under section 6011.