Αποτελέσματα Αναζήτησης
Highlights of Final Section 6111 Regulations: Regulation § 301.6111 has been amended to include § 301.6111-3. A material advisor is defined as a person who provides any material aid, assistance or advice with respect to organizing, managing, promoting, selling, implementing, insuring or carrying out any reportable transaction, and directly or ...
20 Ιουν 2024 · This section provides guidance for Small Business and Self-Employed (SB/SE) Examination area office employees, Tax Exempt and Governmental Entities (TE/GE) employees, Taxpayer Services (TS), and Large Business and International (LB&I) employees who are examining abusive transactions.
11 Σεπ 2024 · Treasury regulations require that certain tax shelters and transactions be registered and that lists of investors be maintained by parties who organize or sell interests in the shelter (s).
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.
“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.”
The IRS recently promulgated the final version of the triumvirate of provisions commonly referred to as the “tax shelter regulations.” These regulations were prompted by changes to Section 6111, which, after a decade of near-hibernation, was amended in 1997 to require the registration of certain “confidential arrangements.”
