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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)
- 26 U.S. Code § 6110 - Public inspection of written determinations
If the Secretary of the Treasury by regulation provides...
- 26 CFR § 301.6111-3 - Disclosure of reportable transactions.
For a protective disclosure to be effective, the advisor...
- 26 U.S. Code § 6110 - Public inspection of written determinations
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 ...
Sec. 6111. Disclosure Of Reportable Transactions. I.R.C. § 6111 (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— I.R.C. § 6111 (a) (1) — information identifying and describing the transaction, I.R.C. § 6111 (a) (2) —
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--
1 Φεβ 2022 · A listed transaction is defined in Regs. Sec. 1. 6011-4 (b)(2) as a transaction that is the same or similar to one that the IRS has determined to be a tax-avoidance transaction and identified in a notice, regulation, or other publication.
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.
SECTION 1. PURPOSE. This revenue procedure provides that certain transactions with brief asset holding periods are not reportable transactions for purposes of the disclosure rules under. § 1.6011-4(b)(7) of the Income Tax Regulations.
