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treasury issues tax shelter regulations
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As part of its ongoing efforts to address abusive tax avoidance transactions (read: tax shelters), the Treasury Department and the Internal Revenue Service just released amended disclosure and list maintenance regulations. The amended regulations strengthen the rules for the disclosure by taxpayers of their participation in potentially- abusive tax avoidance transactions and the maintenance of lists by promoters of such transactions. Under the amended regulations, taxpayers will be required to disclose - and promoters will be required to maintain investor lists for - six categories of transactions, including listed transactions; transactions with contractual protections; and transactions marketed under conditions of confidentiality.
The proposed regulations will amend the existing temporary regulations under section 6011 (taxpayer disclosure) and 6112 (promoter list maintenance) of the Code. Pending legislation would permit the Treasury Department to require promoters to register these same types of transactions with the IRS. The Treasury Department will amend the regulations under section 6111 (promoter registration) when such legislation is enacted.
Copies of both regulations are in the pdf files below. For additional information, contact Mark Prysock at mprysock@FinancialExecutives.org.
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