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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 ...
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.
Section. 26 U.S. Code § 6111 - Disclosure of reportable transactions. U.S. Code. Notes. prev | next. (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— (1) information identifying and describing the transaction, (2)
A material advisor required to file a disclosure statement under this section must file a completed Form 8918, “Material Advisor Disclosure Statement” (or successor form) in accordance with this paragraph (d) and the instructions to the form.
1 Φεβ 2022 · Under Regs. Sec. 1. 6011-4 (d), a taxpayer discloses a reportable transaction by attaching Form 8886, Reportable Transaction Disclosure Statement, to the tax return. To be considered complete, the information provided on Form 8886 must:
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-
Sec. 301.6111-2 Confidential corporate tax shelters. (a) 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). (2) A confidential corporate tax shelter is any transaction--
