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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).


Page Last Reviewed or Updated: 20-Mar-2015