Reportable transactions / Todd C. Simmens CPA, Esq., Woodbridge, NJ, and Jeffrey H. Paravano, Esq., Washington, DC.
2018
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Details
Author
Title
Reportable transactions / Todd C. Simmens CPA, Esq., Woodbridge, NJ, and Jeffrey H. Paravano, Esq., Washington, DC.
Added Author
Added Corporate Author
Imprint
Arlington, VA : Tax Management Inc., [2018]-
Description
1 online resource.
Frequency
Updated irregularly
Series
Tax management portfolios ; 648-2nd.
Formatted Contents Note
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.
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.
Summary
" ... 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 rules under [section] 6111 and [section] 6112, as well as associated penalties, are addressed. Finally, the Portfolio addresses record retention and requirements for reporting of uncertain tax positions."
Bibliography, etc. Note
Includes bibliographical references.
Linking Note
Merger of: Reportable transactions, and: Tax shelters.
Location
www
Linked Resources
Alternate Title
BNA Premier package.
Language
English
Record Appears in