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For purposes of determining whether any investment is a tax shelter by reason of section 6111(c)(1)(B)(iii) of such Code (as added by this section), only offers for sale after August 31, 1984, shall be taken into account.
To be considered complete, the form must describe the expected tax treatment and all potential tax benefits expected to result from the transaction, describe any tax result protection with respect to the transaction, and identify and describe the transaction in sufficient detail for the IRS to understand the tax structure of the reportable ...
shelters under section 6111(d). These regulations provide the public with additional guidance needed to comply with the disclosure rules under section 6011(a), the registration requirement under section 6111(d), and the list maintenance requirement under section 6112 applicable to tax shelters. The
4 mar 2003 · In particular, the IRS and Treasury Department reviewed the commentators’ suggested clarifications to the rules pertaining to loss transactions and transactions with a significant book-tax difference, and to the rules pertaining to who must disclose transactions under section 6011. The IRS and
(D) A material advisor who the potential material advisor knows is or reasonably expects to be required to disclose the transaction under this section because the transaction is or is reasonably expected to become a transaction described in § 1.6011-4(b)(3) through (5) or (7) of this chapter.
Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth— information identifying and describing the transaction, information describing any potential tax benefits expected to result from the transaction, and.
4 paź 2024 · 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) information describing any potential tax benefits expected to result from the transaction, and.
