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Lane
Lane, JD, CFP, MBA, CRPS
Category: Tax
Satisfied Customers: 10172
Experience:  Law Degree, specialization in Tax Law and Corporate Law, CFP and MBA, Providing Financial & Tax advice since 1986
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Can anyone tell me what are they asking by this regulation,

This answer was rated:

Can anyone tell me what are they asking by this regulation , the reason I might not understantand is because it doesn't pertain to my industry. But I want to make sure that I understand what they are asking and learn a little about this regulation they IRS gives you a lot but really confusing I would like it descrive in a not shell.
Thanks ,
Surely
Details of any “reportable transactions” required to be disclosed pursuant to Treas. Reg. §1.6011-4.

What is the regulation?

Customer: replied 4 months ago.

Details of any “reportable transactions” required to be disclosed pursuant to Treas. Reg. §1.6011-4.

I will opt out so an expert that deals with this can advise

Hi,

..

In general. A reportable transaction is a transaction described in any of the paragraphs (b)(2) through (7) of this section (§1.6011-4.) The term transaction includes all of the factual elements relevant to the expected tax treatment of any investment, entity, plan, or arrangement, and includes any series of steps carried out as part of a plan.

...

THe statute then goes on to list the following:

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(2) Listed transactions

(3) Confidential transactions

(4) Transactions with contractual protection

(5) Loss transactions

(6) Transactions of interest

(7 is a currently reserved section)

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This section can deal wiith MANY possible areas; tax shelters, qualified plans, essentiallly any item that a taxing authority (IRS here) determins as follows:

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"Reportable transaction" means any transaction or arrangement with respect to which information is required to be included with a tax return or statement because, as determined under regulations prescribed pursuant to this act, such transaction or arrangement is of a type which 1) the commissionner determines as having a potential for avoidance or evasion of the tax imposed by tax law, whether through deduction or credit, the excludability or omission of any income, the manipulation of any allocation or apportionment rule, or the securing of any other tax benefit.

2) is carried out through or invested in by at least one entity or person that is doing business in the US or any US state, deriving income from sources in the US, subject to any part of title 26 (the US tax code), or is otherwise subject to the jurisdiction of this IRS

Depending on your context here, you aere likely dealing with something that, either, has been determined to be a tax avoidane technique OR is in some other way being determined to be a plan.

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What's the context, the surrounding facts? (What's this about)?

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And I may be able to be more specific

Did this help? Can you give me the context, the surrounding facts?

Lane, JD, CFP, MBA, CRPS
Category: Tax
Satisfied Customers: 10172
Experience: Law Degree, specialization in Tax Law and Corporate Law, CFP and MBA, Providing Financial & Tax advice since 1986
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