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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.
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 · Describe any tax result protection (as defined in Regs. Sec. 301. 6111-3 (c)(12)) for the transaction; and Identify and describe the transaction in sufficient detail for the IRS to be able to understand the tax structure of the reportable transaction and the identity of all parties involved in it.
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)
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.
To register a confidential corporate tax shelter, the person responsible for registering the tax shelter must file Form 8264, “Application for Registration of a Tax Shelter”. (Form 8264 is also used to register tax shelters defined in section 6111 (c).)
