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If more than one material advisor is required to disclose a reportable transaction under § 6111, the material advisors may designate by written agreement a single material advisor to disclose the transaction.
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.
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,
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.
27 mar 2017 · the IRS as required under 4IRC section 6011, or else a material adviser. provides the IRS with certain information under IRC section 6112. 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
3 sie 2007 · 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.
To register a confidential corporate tax shelter, the person responsible for registering the tax shelter must file Form 8264, “Application for Registration of a Tax Shelter”. (Form 8264 is also used to register tax shelters defined in section 6111 (c).)
