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 ...
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.
“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.”
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.
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:
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,
Title 26: Internal Revenue. PART 1—INCOME TAXES. tax returns or statements. 1.6011-4 Requirement of statement disclosing participation in certain transactions by taxpayers. In general.
