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  1. 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 ...

  2. (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]]

  3. 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--

  4. 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.

  5. 20 Σεπ 2024 · Section 6111 - Disclosure of reportable transactions. (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-.

  6. 2 Νοε 2006 · This document contains temporary and final regulations under sections 6011, 6111, and 6112 of the Internal Revenue Code that modify the rules relating to the disclosure of reportable transactions and the list maintenance requirements.

  7. 4 Μαρ 2003 · This document amends 26 CFR part 1 to provide rules. relating to the disclosure of reportable transactions by. certain taxpayers on their Federal tax returns under section. 6011, and also amends 26 CFR parts 20, 25, 31, 53, 54, and 56. to provide rules for purposes of estate, gift, employment, and.

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