Definition of Party and Allocation of Net Income or Proceeds for Purposes of Code Section 4965
Notice 2007-18 provides guidance, for purposes of Internal Revenue Code section 4965, to exempt and other organizations that may be parties to prohibited tax shelter transactions. Notice 2007-18 addresses the following issues:
- The meaning of tax-exempt party to a prohibited tax shelter transaction for purposes of section 4965 and related disclosure provisions; and
- The appropriate treatment of net income or proceeds received before the effective date of the tax in section 4965(a).