Αποτελέσματα Αναζήτησης
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 ...
if the person is required to register the transaction under section 6111; or the person receives or expects to receive at least a minimum fee (as defined in paragraph (c)(3) of this section) with respect to the transaction, and the person makes a tax statement (as defined in paragraph (c)(2)(iii) of this section) to or for the benefit 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) —.
1 Φεβ 2022 · The threshold amount is $50,000 for reportable transactions where substantially all of the tax benefits are provided to natural persons and $250,000 in any other case (Sec. 6111(b)(1); Regs. Secs. 301. 6111-3 (b)(1) and (b)(3)).
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.
For purposes of determining whether any investment is a tax shelter by reason of section 6111(c)(1)(B)(iii) of such Code (as added by this section), only offers for sale after August 31, 1984, shall be taken into account.
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.