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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 ...
The Secretary may prescribe regulations which provide— I.R.C. § 6111 (c) (1) — that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements, I.R.C. § 6111 (c) (2) —
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- (1) information identifying and describing the transaction,
Following the statutory change, the IRS issued Revenue Procedure 2005-26 to provide interim guidance on IRC section 6501(c)(10), by describing procedures for taxpayers to follow in making the proper disclosures in order to start the one-year period.
[T.D. 7533, 43 FR 6603, Feb. 15, 1978] §1.6011–3 Requirement of statement from payees of certain gambling winnings. (a) General rule. Except as provided in paragraph (c) of this section, any per-son receiving a payment with respect to a wager in a sweepstakes, wagering pool, lottery, or other wagering trans-action (including a parimutuel pool
§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,
