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Reportable Transactions Resources - Article
The IRS Says:
516 - 935 - 7346
"Reportable Transactions"
Definitions You Need To Understand
Natural persons who fail
to disclose a reportable
transaction to the IRS
are subject to a $10,000
penalty. Other
nonreporting taxpayers
are subject to a $50,000
penalty.

The penalties are
increased to $100,000
and $200,000,
respectively, for natural
persons and other
taxpayers who fail to
disclose a reportable
transaction that is a
listed transaction
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Expert
    Reportable Transactions Defined by Federal Law


    In accordance with Section 6011 of the Internal Revenue Code and the regulations issued thereunder, any taxpayer that
    has participated in a "reportable transaction" must file a disclosure statement ( IRS Form 8886 ) with the IRS describing
    the transaction and the extent of the taxpayer's participation in the transaction. For purposes of these rules, "reportable
    transactions" include the following:

  • Listed Transactions (including transactions that are substantially similar thereto, construed broadly in favor of
    disclosure).

  • Confidential Transactions (transactions offered to a taxpayer under conditions of confidentiality to protect the
    advisor's tax strategies and the taxpayer pays a minimum fee of $250,000 for a transaction involving a corporate
    taxpayer and generally $50,000 for transactions involving noncorporate taxpayers).

  • Transactions with Contractual Protection (transactions in which a taxpayer has a right to a full or partial refund
    of fees in the event the intended tax consequences of the transaction are not sustained, or if the transaction's fees
    are contingent upon a taxpayer's realization of tax benefits).

  • Loss Transactions. A transaction will be considered a loss transaction requiring disclosure as a "reportable
    transaction" if it purports to give rise to a loss under Section 165 of the Internal Revenue Code of at least $10
    million in any single tax year ($20 million in a combination of tax years) for corporations, or a loss of $2 million in
    any single tax year (or $4 million in a combination of taxable years) for transactions involving individuals, S
    corporations or trusts. A five-year window from the year of loss, going forward, is utilized when determining these
    thresholds.
Call 516 935-7346
Call 516-935-7346