Reportable transactions /
" ... provides an in-depth discussion of the abusive tax avoidance transactions and anti-abuse rules. The reportable transaction taxpayer compliance rules under Reg. [section] 1.6011-4, as well as the associated penalties for noncompliance, are discussed in detail. Material advisor compliance r...
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| Previous Title: | Simmens, Todd C. Reportable transactions. Paravano, Jeffrey H., 1966- Tax shelters. |
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| Main Author: | |
| Corporate Author: | |
| Other Authors: | |
| Format: | Online |
| Language: | English |
| Published: |
Arlington, VA :
Tax Management Inc.,
[2018]-
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| Series: | Tax management portfolios ;
648-2nd |
| Subjects: | |
| Online Access: | https://www.bloomberglaw.com/product/tax/citation/tm%20648 |
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Table of Contents:
- Detailed analysis. Overview
- Defining abusive tax avoidance transactions and identifying compliance issues
- Goals of certain tax minimization strategies
- Anti-abuse rules separate from the reportable transaction rules and economic substance codification
- Codification of the economic substance doctrine
- Reportable transaction categories
- Listed transactions in detail
- Transactions with contractual protection
- Confidential transactions
- Loss transactions
- Transactions of interest
- Patented tax transactions
- Compliance procedures
- Protective disclosures
- Penalties related to reportable transactions
- Private letter ruling requests
- Exceptions from reporting
- Record retention
- Sections 6111 and 6112--reporting and list maintenance by material advisors
- State law
- Reporting of uncertain tax positions
- Working papers