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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 ...
4 mar 2003 · This document amends 26 CFR part 1 to provide rules. relating to the disclosure of reportable transactions by. certain taxpayers on their Federal tax returns under section. 6011, and also amends 26 CFR parts 20, 25, 31, 53, 54, and 56. to provide rules for purposes of estate, gift, employment, and.
1 lut 2022 · Regs. Sec. 1. 6011 - 4 provides that taxpayers who are required to file a tax return and that participate in a "reportable transaction" for any tax year must disclose information about the transaction to the IRS in a manner and time specified in the regulations.
For a protective disclosure to be effective, the taxpayer must comply with these disclosure regulations by providing to the IRS all information requested by the IRS under this section. (g) Retention of documents.
The Treasury Regulations under § 1.6011-4 specify the types of transactions that are considered reportable transactions. Among these transactions are transactions of interest, i.e., transactions that are the same or substantially similar to a transaction the IRS has identified as a transaction of interest by notice,
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, I.R.C. § 6111 (a) (2) —
