6011-4(e) (2) appears to require disclosure to OTSA
within 90 days after the transaction is identified as either a transaction of interest or a listed transaction, that is not always the case.
Form 8918, Material Advisor Disclosure Statement, must be filed with the OTSA
by the last day of the month that follows the end of the calendar quarter in which an adviser became a material adviser with respect to the TOI or in which the circumstances necessitating an amended disclosure occur (Regs.
File with the OTSA
within 45 calendar days of the return due date: The disclosure must be made to the OTSA
within 45 calendar days of the return's due date, including extension.
6707A penalty will not be imposed until a taxpayer fails to provide (1) the required disclosure statement with an original or amended return or (2) a copy to the OTSA
(if applicable), even if the return is filed after the due date.
CIC taxpayers are to submit the disclosure information to the assigned team manager, with a copy to OTSA
Taxpayers that fail to attach a reportable transaction disclosure statement to an original or amended return and to provide a copy of a required disclosure statement to the OTSA
will be subject to a single penalty under Sec.
PreCheck moves us closer to our goal of delivering the most effective and efficient screening by recognizing most passengers do not pose a threat to security,O Pistole said.
Harris announced that more than 50 disclosure statements relating to transactions involving more than $4 billion had been filed with the OTSA
If a transaction becomes a reportable transaction on or after the date the taxpayer has filed the return for the first tax year for which the transaction affected a taxpayer's, partner's or shareholder's tax liability, the disclosure statement must be filed as an attachment to the return next filed after the date the transaction becomes a reportable transaction; a copy of the disclosure statement must also be filed with the OTSA
The free-flowing meeting covered everything from how the OTSA
(which is still in formation) will treat taxpayer disclosures under the temporary regulations to the use of pre-filing agreements, industry issue resolution, and other innovative tools in providing guidance to taxpayers on transactions the IRS questions and mounting an effective (and fair) enforcement effort.
In our view, it is unclear whether the OTSA
(or the Large & Mid-Size Business Division) will have the resources or expertise to routinely inject itself into all large-case examinations involving disclosures under these regulations.
concept was not part of the original conceptual design for the IRS.