In August 2007, the IRS released final regulations modifying the rules relating to disclosure of reportable transactions under Section 6011, material advisors responsible for disclosing reportable transactions under Section 6111, and list maintenance requirements under Section 6112.
We summarizes modifications made to the prior Section 6011 regulations regarding the disclosure of reportable transactions, including disclosures that taxpayers may be considering for tax returns expected to be filed.
This article also addresses timing issues related to disclosure of newly identified listed transactions and transactions of interest and emphasizes that a more regular review may be required to ensure proper disclosure and avoidance of penalties.
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