Αποτελέσματα Αναζήτησης
“The amendment made by this section [amending this section] shall apply to any tax shelter (within the meaning of section 6111 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] as amended by this section) interests in which are first offered for sale after December 31, 1986.”
I.R.C. § 6111 (b) (1) (A) In General —. The term “material advisor” means any person—. I.R.C. § 6111 (b) (1) (A) (i) —. who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and.
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 Φεβ 2022 · A copy of the disclosure statement must be sent to the IRS Office of Tax Shelter Analysis (OTSA) at the same time that the taxpayer first files any disclosure statement pertaining to a particular reportable transaction (Regs. Sec. 1. 6011-4 (e)).
1 Ιαν 2024 · Internal Revenue Code § 6111. Disclosure of reportable transactions. Current as of January 01, 2024 | Updated by FindLaw Staff. (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--
§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- (1) information identifying and describing the transaction,
