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.”
(f) Designation agreements. If more than one material advisor is required to disclose a reportable transaction under this section, the material advisors may designate by written agreement a single material advisor to disclose the transaction.
Subchapter B. § 6111. 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,
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.
1 Φεβ 2022 · The IRS determines whether the ruling request itself satisfies the disclosure requirement (Regs. Sec. 1. 6011-4 (f)(1)). A taxpayer may make a protective disclosure by following the requirements of this rule.
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.
