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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.
1 lut 2022 · A reportable transaction is any transaction for which the IRS requires information to be included with a return or statement because the Service has determined, pursuant to the regulations under Sec. 6011, that the transaction is of a type that has the potential for tax avoidance or evasion (Sec. 6707A (c) (1)).
20 wrz 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- (1) information identifying and describing the transaction,
A taxpayer’s disclosure under IRC section 6011 is generally made by filing a Form 8886, "Reportable Transaction Disclosure Statement," with the required information and attaching it to the tax return for each taxable year in which a listed transaction occurred.
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.
