Αποτελέσματα Αναζήτησης
If more than one material advisor is required to disclose a reportable transaction under § 6111, the material advisors may designate by written agreement a single material advisor to disclose the transaction.
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 ...
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.
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) —
In general. (1) Under section 6111(d) and this section, a confidential corporate tax shelter is treated as a tax shelter subject to the requirements of sections 6111 (a) and (b).
(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. (2) Transaction that has a potential for tax avoidance or evasion-- In general. [[Page 138]]
To register a confidential corporate tax shelter, the person responsible for registering the tax shelter must file Form 8264, “Application for Registration of a Tax Shelter”. (Form 8264 is also used to register tax shelters defined in section 6111 (c).)
