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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. However, these transactions may be
“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.”
(1) information identifying and describing the transaction, (2) information describing any potential tax benefits expected to result from the trans-action, and (3) such other information as the Secretary may prescribe. Such return shall be filed not later than the date specified by the Secretary. (b) Definitions For purposes of this section:
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--
Section 6111(b)(1), as amended, provides a definition for the term material advisor and includes as part of that definition a requirement that the material advisor derive certain threshold amounts of gross income that the Secretary may prescribe.
quired pursuant to section 3402(q) or 6041, as the case may be. (b) Contents of statement. The state-ment referred to in paragraph (a) shall contain information (in addition to that required under section 6041(c)) as to the amount, if any, of winnings from identical wagers to which the recipient is entitled. If any person other than
Internal Revenue Code 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- (1) information identifying and describing the transaction,
