" ... 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.
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.