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26 U.S.C. § 6111 — Disclosure of reportable transactions
Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth—
(1) information identifying and describing the transaction,
(2) information describing any potential tax benefits expected to result from the transaction, and
(3) such other information as the Secretary may prescribe.
Such return shall be filed not later than the date specified by the Secretary.
**(b) Definitions** For purposes of this section:
(1) **Material advisor**
(A) *In general* — The term “material advisor” means any person—
(i) who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and
(ii) who directly or indirectly derives gross income in excess of the threshold amount (or such other amount as may be prescribed by the Secretary) for such aid, assistance, or advice.
(B) *Threshold amount* — For purposes of subparagraph (A), the threshold amount is—
(i) $50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and
(ii) $250,000 in any other case.
(2) **Reportable transaction** — The term “reportable transaction” has the meaning given to such term by section 6707A(c).
**(c) Regulations** The Secretary may prescribe regulations which provide—
(1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements,
(2) exemptions from the requirements of this section, and
(3) such rules as may be necessary or appropriate to carry out the purposes of this section.
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Source location: Title 26, Chapter 61, § 6111; chapter-061-information-and-returns.md
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**(a) In general** Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth—
(1) information identifying and describing the transaction,
(2) information describing any potential tax benefits expected to result from the transaction, and
(3) such other information as the Secretary may prescribe.
Such return shall be filed not later than the date specified by the Secretary.
**(b) Definitions** For purposes of this section:
(1) **Material advisor**
(A) *In general* — The term “material advisor” means any person—
(i) who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and
(ii) who directly or indirectly derives gross income in excess of the threshold amount (or such other amount as may be prescribed by the Secretary) for such aid, assistance, or advice.
(B) *Threshold amount* — For purposes of subparagraph (A), the threshold amount is—
(i) $50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and
(ii) $250,000 in any other case.
(2) **Reportable transaction** — The term “reportable transaction” has the meaning given to such term by section 6707A(c).
**(c) Regulations** The Secretary may prescribe regulations which provide—
(1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements,
(2) exemptions from the requirements of this section, and
(3) such rules as may be necessary or appropriate to carry out the purposes of this section.
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Federal law — U.S. Code and appendices · legal_authorities
For purposes of section 38, the amount of the investment credit determined under this section for any taxable year shall be the sum of—
(1) the rehabilitation credit,
(2) the energy credit,
(3) the qualifying advanced coal project credit,
(4) the qualifying gasification project credit,
(5) the qualifying advanced energy project credit,
(6) the advanced manufacturing investment credit, and
(7) the clean electricity investment credit.
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 46
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Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** If a person who is required to file a return under section 6111(a) with respect to any reportable transaction—
(1) fails to file such return on or before the date prescribed therefor, or
(2) files false or incomplete information with the Secretary with respect to such transaction,
such person shall pay a penalty with respect to such return in the amount determined under subsection (b).
**(b) Amount of penalty**
(1) **In general** — Except as provided in paragraph (2), the penalty imposed under subsection (a) with respect to any failure shall be $50,000.
(2) **Listed transactions** — The penalty imposed under subsection (a) with respect to any listed transaction shall be an amount equal to the greater of—
(A) $200,000, or
(B) 50 percent of the gross income derived by such person with respect to aid, assistance, or advice which is provided with respect to the listed transaction before the date the return is filed under section 6111.
Subparagraph (B) shall be applied by substituting “75 percent” for “50 percent” in the case of an intentional failure or act described in subsection (a).
**(c) Rescission authority** The provisions of section 6707A(d) (relating to authority of Commissioner to rescind penalty) shall apply to any penalty imposed under this section.
**(d) Reportable and listed transactions** For purposes of this section, the terms “reportable transaction” and “listed transaction” have the respective meanings given to such terms by section 6707A(c).
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6707
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** Except as otherwise provided in this section, the depreciation deduction provided by section 167(a) for any tangible property shall be determined by using—
(1) the applicable depreciation method,
(2) the applicable recovery period, and
(3) the applicable convention.
**(b) Applicable depreciation method** For purposes of this section—
(1) **In general** — Except as provided in paragraphs (2) and (3), the applicable depreciation method is—
(A) the 200 percent declining balance method,
(B) switching to the straight line method for the 1st taxable year for which using the straight line method with respect to the adjusted basis as of the beginning of such year will yield a larger allowance.
(2) **150 percent declining balance method in certain cases** — Paragraph (1) shall be applied by substituting “150 percent” for “200 percent” in the case of—
(A) any 15-year or 20-year property not referred to in paragraph (3),
(B) any property (other than property described in paragraph (3)) which is a qualified smart electric meter or qualified smart electric grid system, or
(C) any property (other than property described in paragraph (3)) with respect to which the taxpayer elects under paragraph (5) to have the provisions of this paragraph apply.
(3) **Property to which straight line method applies** — The applicable depreciation method shall be the straight line method in the case of the following property:
(A) Nonresidential real property.
(B) Residential rental property.
(C) Any railroad grading or tunnel bore.
(D) Property with respect to which the taxpayer elects under paragraph (5) to have the provisions of this paragraph apply.
(E) Property described in subsection (e)(3)(D)(ii).
(F) Water utility property described in
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 168
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Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** Each material advisor (as defined in section 6111) with respect to any reportable transaction (as defined in section 6707A(c)) shall (whether or not required to file a return under section 6111 with respect to such transaction) maintain (in such manner as the Secretary may by regulations prescribe) a list—
(1) identifying each person with respect to whom such advisor acted as a material advisor with respect to such transaction, and
(2) containing such other information as the Secretary may by regulations require.
**(b) Special rules**
(1) **Availability for inspection; retention of information on list** — Any person who is required to maintain a list under subsection (a) (or was required to maintain a list under subsection (a) as in effect before the enactment of the American Jobs Creation Act of 2004)—
(A) shall make such list available to the Secretary for inspection upon written request by the Secretary, and
(B) except as otherwise provided under regulations prescribed by the Secretary, shall retain any information which is required to be included on such list for 7 years.
(2) **Lists which would be required to be maintained by 2 or more persons** — The Secretary may prescribe regulations which provide that, in cases in which 2 or more persons are required under subsection (a) to maintain the same list (or portion thereof), only 1 person shall be required to maintain such list (or portion).
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6112
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Imposition of penalty** If this section applies to any portion of an underpayment of tax required to be shown on a return, there shall be added to the tax an amount equal to 20 percent of the portion of the underpayment to which this section applies.
**(b) Portion of underpayment to which section applies** This section shall apply to the portion of any underpayment which is attributable to 1 or more of the following:
(1) Negligence or disregard of rules or regulations.
(2) Any substantial understatement of income tax.
(3) Any substantial valuation misstatement under chapter 1.
(4) Any substantial overstatement of pension liabilities.
(5) Any substantial estate or gift tax valuation understatement.
(6) Any disallowance of claimed tax benefits by reason of a transaction lacking economic substance (within the meaning of section 7701(o)) or failing to meet the requirements of any similar rule of law.
(7) Any undisclosed foreign financial asset understatement.
(8) Any inconsistent estate basis.
(9) Any overstatement of the deduction provided in section 170(p).
(10) Any disallowance of a deduction by reason of section 170(h)(7).
This section shall not apply to any portion of an underpayment on which a penalty is imposed under section 6663. Except as provided in paragraph (1) or (2)(B) of section 6662A(e), this section shall not apply to the portion of any underpayment which is attributable to a reportable transaction understatement on which a penalty is imposed under section 6662A.
**(c) Negligence** For purposes of this section, the term “negligence” includes any failure to make a reasonable attempt to comply with the provisions of this title, and the term “disregard” includes any careless, reckless, or intentional disregard.
**(d) Substantial understateme
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6662
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Federal law — U.S. Code and appendices · legal_authorities
**(a) Imposition of penalty**
(1) **In general** — If any person who is required to maintain a list under section 6112(a) fails to make such list available upon written request to the Secretary in accordance with section 6112(b) within 20 business days after the date of such request, such person shall pay a penalty of $10,000 for each day of such failure after such 20th day.
(2) **Reasonable cause exception** — No penalty shall be imposed by paragraph (1) with respect to the failure on any day if such failure is due to reasonable cause.
**(b) Penalty in addition to other penalties** The penalty imposed by this section shall be in addition to any other penalty provided by law.
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6708
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Federal law — U.S. Code and appendices · legal_authorities
Page 3492
TITLE 26—INTERNAL REVENUE CODE
§ 6111
Subsec. (l)(1). Pub. L. 106–554, § 1(a)(7) [title III,
§ 304(c)(2)], inserted ‘‘or 6105’’ after ‘‘6104’’.
1999—Subsec. (b)(1). Pub. L. 106–170 inserted at end
‘‘Such term shall not include any advance pricing
agreement entered into by a taxpayer and the Sec-
retary and any background information related to such
agreement or any application for an advance pricing
agreement.’’
1998—Subsec. (b)(1). Pub. L. 105–206, § 3509(a), sub-
stituted ‘‘technical advice memorandum, or Chief
Counsel advice’’ for ‘‘or technical advice memo-
randum’’.
Subsec. (f)(1). Pub. L. 105–206, § 3509(c)(1), substituted
‘‘Except as otherwise provided by subsection (i), the
Secretary’’ for ‘‘The Secretary’’.
Subsec. (i). Pub. L. 105–206, § 3509(b), added subsec. (i).
Former subsec. (i) redesignated (j).
Subsec. (j). Pub. L. 105–206, § 3509(b), redesignated sub-
sec. (i) as (j). Former subsec. (j) redesignated (k).
Subsec. (j)(1)(B), (2). Pub. L. 105–206, § 3509(c)(2), sub-
stituted ‘‘subsection (g) or (i)(4)(B)’’ for ‘‘subsection
(g)’’.
Subsec. (k). Pub. L. 105–206, § 3509(b), redesignated
subsec. (j) as (k). Former subsec. (k) redesignated (l).
Subsec. (k)(1)(B). Pub. L. 105–206, § 3509(c)(3), sub-
stituted ‘‘subsection (c)(1) or (i)(3)’’ for ‘‘subsection
(c)’’.
Subsecs. (l), (m). Pub. L. 105–206, § 3509(b), redesig-
nated subsecs. (k) and (l) as (l) and (m), respectively.
1984—Subsec. (f)(5). Pub. L. 98–620 struck out provi-
sion that the Court of Appeals had to expedite any re-
view of such decision in every way possible.
1982—Subsec. (i)(1). Pub. L. 97–164 substituted ‘‘United
States Claims Court’’ for ‘‘Court of Claims’’.
Statutory Notes and Related Subsidiaries
EFFECTIVE DATE OF 2007 AMENDMENT
Pub. L. 110–172, § 10(b), De
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6111
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