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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 ...
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)
steps carried out as part of a plan. (1) Transaction that is a section 6111 tax shelter. A section 6111 tax shelter is any transaction that is required to be registered with the IRS under section 6111, regardless of whether that tax shelter is properly registered pursuant to section 6111.
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.
1 Φεβ 2022 · Secs. 6111 and 6112 further require any material adviser with respect to a reportable transaction to disclose information about the transaction to the IRS and to maintain a list of persons he or she has advised with respect to it.
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, I.R.C. § 6111 (a) (2) —
Material advisors with respect to the transaction are required to disclose the transaction under I.R.C. § 6111 and maintain a list of their advisees under I.R.C. § 6112.