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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,
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.
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.
The general statutory period under Internal Revenue Code (IRC) section 6501 (a) for making an assessment of tax is three years from the date a tax return is due (or from when a return was filed, if later). The expiration of the statute of limitations will foreclose the IRS from making changes to a taxpayer’s reported liability for any tax period.
§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,
