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 ...
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.
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.
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.
(1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements, (2)
Section 6111 (d), the initial impetus for the tax shelter regulations, has become Treasury’s greatest limitation, because it is the only of the three relevant Code provisions which is limited on its face to corporate transactions.
