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.
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.
Section 1. Purpose. This revenue procedure provides guidance relating to the obligation of material advisors to prepare and maintain lists with respect to reportable transactions under § 6112 of the Internal Revenue Code.
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.
Service (IRS) has determined to be a tax avoidance transaction and identi-fied by notice, regulation, or other form of published guidance as a listed transaction. If a transaction becomes a listed transaction after the date on which registration would otherwise be required under this section, and if the transaction otherwise satisfies the con-
31 Ιουλ 2022 · Transfers (GST) Section 6011 Regulations and Amendments to the Section 6112 Regulations AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Final regulations. SUMMARY: This document contains fi-nal regulations that provide rules relating to the disclosure of listed transactions and transactions of interest with respect to
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.
