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 ...
“The amendment made by this section [amending this section] shall apply to any tax shelter (within the meaning of section 6111 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] as amended by this section) interests in which are first offered for sale after December 31, 1986.”
“Any person who fails to include an identification number on a return on which such number is required to be included under section 6111(b)(2) shall pay a penalty of $250 for each such failure, unless such failure is due to reasonable cause.”
1 Φεβ 2022 · The penalty is $1,000 or, if the person can establish that it is less, 100% (50% for allowability statements) of the gross income derived by the person from the activity related to the entity, plan, or arrangement (Sec. 6700(a)(2)).
Section 301.6112-1(e)(1). Section 6708(a) provides that if any person who is required to maintain a list fails to make the list available to the IRS within 20 business days after the date of the written request, the person shall pay a penalty of $10,000 for each day of the failure after the expiration of the 20th business day.
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.
