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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.
1 lut 2022 · The IRS determines whether the ruling request itself satisfies the disclosure requirement (Regs. Sec. 1. 6011-4 (f)(1)). A taxpayer may make a protective disclosure by following the requirements of this rule.
IRC section 6112 requires material advisers to maintain lists of advisees and other information related to reportable transactions and to provide it to the IRS upon a written request.
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 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).
Subchapter B. § 6111. Sec. 6111. Disclosure Of Reportable Transactions. I.R.C. § 6111 (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— I.R.C. § 6111 (a) (1) — information identifying and describing the transaction,
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,
