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26 U.S.C. § 6112 — Material advisors of reportable transactions must keep lists of advisees, etc.
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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Stable record: federal_law:legal_authorities:record_usc_5ad36ac62fea68e10d2a087a
Source file: Laws/federal/codes/united-states-code/title-26/section-6112-material-advisors-of-reportable-transactions-must-keep-lists-of-advisees--7086b5909c.md
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Source location: Title 26, Chapter 61, § 6112; chapter-061-information-and-returns.md
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**(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).
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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.
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6111
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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
**(a) Limitation based on amount of tax** The aggregate amount of credits allowed by this subpart for the taxable year shall not exceed the sum of—
(1) the taxpayer’s regular tax liability for the taxable year reduced by the foreign tax credit allowable under section 27, and
(2) the tax imposed by section 55(a) for the taxable year.
**(b) Regular tax liability** For purposes of this part—
(1) **In general** — The term “regular tax liability” means the tax imposed by this chapter for the taxable year.
(2) **Exception for certain taxes** — For purposes of paragraph (1), any tax imposed by any of the following provisions shall not be treated as tax imposed by this chapter:
(A) section 55 (relating to minimum tax),
(B) section 59A (relating to base erosion and anti-abuse tax),
(C) subsection (m)(5)(B), (q), (t), or (v) of section 72 (relating to additional taxes on certain distributions),
(D) section 143(m) (relating to recapture of proration of Federal subsidy from use of mortgage bonds and mortgage credit certificates),
(E) section 530(d)(4) (relating to additional tax on certain distributions from Coverdell education savings accounts),
(F) section 531 (relating to accumulated earnings tax),
(G) section 541 (relating to personal holding company tax),
(H) section 1351(d)(1) (relating to recoveries of foreign expropriation losses),
(I) section 1374 (relating to tax on certain built-in gains of S corporations),
(J) section 1375 (relating to tax imposed when passive investment income of corporation having subchapter C earnings and profits exceeds 25 percent of gross receipts),
(K) subparagraph (A) of section 7518(g)(6) (relating to nonqualified withdrawals from capital construction funds taxed at highest marginal rate),
(L) sections 87
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 26
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Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** Each fundraising solicitation by (or on behalf of) an organization to which this section applies shall contain an express statement (in a conspicuous and easily recognizable format) that contributions or gifts to such organization are not deductible as charitable contributions for Federal income tax purposes.
**(b) Organizations to which section applies**
(1) **In general** — Except as otherwise provided in this subsection, this section shall apply to any organization which is not described in section 170(c) and which—
(A) is described in subsection (c) (other than paragraph (1) thereof) or (d) of section 501 and exempt from taxation under section 501(a),
(B) is a political organization (as defined in section 527(e)), or
(C) was an organization described in subparagraph (A) or (B) at any time during the 5-year period ending on the date of the fundraising solicitation or is a successor to an organization so described at any time during such 5-year period.
(2) **Exception for small organizations**
(A) *Annual gross receipts do not exceed $100,000* — This section shall not apply to any organization the gross receipts of which in each taxable year are normally not more than $100,000.
(B) *Multiple organization rule* — The Secretary may treat any group of 2 or more organizations as 1 organization for purposes of subparagraph (A) where necessary or appropriate to prevent the avoidance of this section through the use of multiple organizations.
(3) **Special rule for certain fraternal organizations** — For purposes of paragraph (1), an organization described in section 170(c)(4) shall be treated as described in section 170(c) only with respect to solicitations for contributions or gifts which are to be used exclusively for purposes referr
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6113
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Federal law — U.S. Code and appendices · legal_authorities
Page 3494
TITLE 26—INTERNAL REVENUE CODE
§ 6112
ability to act under paragraph (1) of section 6111(b) of
such Code (as added by this section) which would (but
for this sentence) arise before such date shall be
deemed to arise on December 31, 1984.’’
§ 6112. Material advisors of reportable trans-
actions must keep lists of advisees, etc.
(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 regula-
tions 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 in-
formation 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 ef-
fect before the enactment of the American
Jobs Creation Act of 2004)—
(A) shall make such list available to the
Secretary for inspection upon written re-
quest by the Secretary, and
(B) except as otherwise provided under reg-
ulations 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 main-
tained 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 2024 U.S. Code historical extraction · 26 U.S.C. § 6112
Stored review status: historical_2024_not_currentness_verified. Same stored citation; legal effect and authority still require review.