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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

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
Email an
    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

  • 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
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