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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 ...
“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.”
25 Απρ 2024 · General information on 401 (k) plans. Starting up your plan. What to know before adopting a plan. Plan qualification requirements. Language needed in your plan. Contribution limits. 401 (k) plan contribution limits, catch-up contributions and excess deferrals. General distribution rules.
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) —.
27 Μαρ 2017 · The general statutory period under Internal Revenue Code (IRC) section 6501(a) for making an assessment of tax is three years from the date a tax return is due (or from when a return was filed, if later).
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.
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.
