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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 ...
(1) Transaction that is a section 6111 tax shelter. 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-- (i) In general. [[Page 138]]
Sec. 301.6111-2 Confidential corporate tax shelters. (a) In general.--(1) Under section 6111(d) and this section, a confidential corporate tax shelter is treated as a tax shelter subject to the requirements of sections 6111 (a) and (b). (2) A confidential corporate tax shelter is any transaction--
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).
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)
In the July 2007 regulations, the IRS and Treasury Department amended 26 CFR parts 20, 25, 31, 53, 54, and 56 to provide that certain taxpayers would be required to disclose transactions of interest, in addition to listed transactions, on their Federal tax returns under section 6011.
The Secretary may prescribe regulations which provide— (1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would other-wise be required to meet such requirements, (2) exemptions from the requirements of this section, and (3) such rules as may be necessary or appro-
