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Highlights of Final Section 6011 Regulations: New reportable transaction category for “transactions of interest” (TOI) which is a transaction that IRS and Treasury believe has a potential for tax avoidance, but for which they lack enough information to determine whether the transaction should be identified specifically as a tax avoidance ...
8 paź 2024 · On June 28, 2024, the Treasury Department and the IRS finalized these regulations in TD 9999 (89 FR 54284). ... the final regulations will not have a significant economic impact on these entities because the final regulations implement sections 6111 and 6112 and Sec. 1.6011-4 by specifying the manner in which and time at which an identified ...
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 IRS has issued final regulations identifying certain syndicated conservation easement transactions and substantially similar transactions as listed transactions under IRC Sections 6111 and 6112.The IRS previously identified certain syndicated conservation easement transactions as listed transactions in Notice 2017-10.The issuance of these final regulations clarifies that participants and ...
30 gru 2022 · T.D. 10007. Background. On December 8, 2022, the IRS issued proposed regulations (REG-106134-22) that identify certain syndicated conservation easement transactions and substantially similar transactions as "listed transactions" for purposes of Reg. Sec. 1.6011-4 (b) (2) and Code Secs. 6111 and 6112.
4 mar 2003 · proposed regulations regarding sections 6011, 6111, and 6112 (TD 8877, REG-103735-00; TD 8876, REG-110311-98; TD 8875, REG- 103736-00) (the February 2000 regulations).
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.
