Regulations - Prohibited Tax Shelter Transactions
The Treasury Department and Internal Revenue Service have issued regulations under Internal Revenue Code sections 4965, 6033, and 6011. Section 4965 imposes excise taxes and disclosure requirements with respect to prohibited tax shelter transactions to which tax-exempt entities are parties. The new regulations provide (1) guidance regarding the definition of "party to a prohibited tax shelter transaction;" (2) rules regarding the form, manner, and timing of disclosure obligations; and (3) return requirements accompanying payment of excise taxes.
- Notice 2006-65 (describing provisions of Code section 4965)
Notice 2007-18 (definition of party and allocation of net income or proceeds for purposes of section 4965)