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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.
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) —. exemptions from the requirements of this section, and. I.R.C. § 6111 (c) (3) —.
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-.
4 mar 2003 · In particular, the IRS and Treasury Department reviewed the commentators’ suggested clarifications to the rules pertaining to loss transactions and transactions with a significant book-tax difference, and to the rules pertaining to who must disclose transactions under section 6011. The IRS and
1 lut 2022 · Secs. 6111 and 6112 further require any material adviser with respect to a reportable transaction to disclose information about the transaction to the IRS and to maintain a list of persons he or she has advised with respect to it.
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.
