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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.
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 ...
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,
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.
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-.
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. I.R.C. § 6111 (b) (1) (A) (ii) —
Title 26: Internal Revenue. PART 1—INCOME TAXES. tax returns or statements. 1.6011-4 Requirement of statement disclosing participation in certain transactions by taxpayers. In general.
