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Except as provided in paragraph (2), the amendments made by this section [amending this section and sections 6662 and 6707 of this title] shall apply to any tax shelter (as defined in section 6111(d) of the Internal Revenue Code of 1986, as amended by this section) interests in which are offered to potential participants after the Secretary of ...
Highlights of Final Section 6111 Regulations: Regulation § 301.6111 has been amended to include § 301.6111-3. A material advisor is defined as a person who provides any material aid, assistance or advice with respect to organizing, managing, promoting, selling, implementing, insuring or carrying out any reportable transaction, and directly or ...
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.
AGENCY: Internal Revenue Service (IRS), Treasury. ACTION: Temporary regulations. SUMMARY: These temporary regulations modify the rules relating to the requirement that certain corporate taxpayers file a statement with their Federal corporate income tax returns under section 6011(a) and the registration of confidential corporate tax
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.
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.
1 sty 2024 · 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-- (3) such other information as the Secretary may prescribe. Such return shall be filed not later than the date specified by the Secretary.
