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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 ...
“Any person claiming any deduction, credit, or other tax benefit by reason of a tax shelter shall include (in such manner as the Secretary may prescribe) on the return of tax on which such deduction, credit, or other benefit is claimed the identification number assigned by the Secretary to such tax shelter.
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.
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 attaching it to the tax return for each taxable year in which a listed transaction occurred.
1 sty 2024 · Internal Revenue Code § 6111. Disclosure of reportable transactions. Current as of January 01, 2024 | Updated by FindLaw Staff. (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--
This revenue procedure provides guidance relating to the obligation of material advisors to prepare and maintain lists with respect to reportable transactions under § 6112 of the Internal Revenue Code.
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,
