AJCA Modifications to Disclosure of Reportable Transactions and List Maintenance Requirements

Reportable Transaction Disclosure Statements

Material Advisor Disclosure Statements

Penalties Associated with Reportable Transactions

  • § 301.6700 Promoting Abusive Tax Shelters The penalty is for a promoter of an abusive tax shelter and is generally equal to $1,000 for each organization or sale of an abusive plan or arrangement  (or, if lesser, 100 percent of the income derived from the activity).
  • § 301.6701 Penalties for aiding and abetting understatement of tax liability The penalty is $1000 ($10,000 if the conduct relates to a corporation’s tax return) for aiding and abetting in an understatement of a tax liability.  Any person subject to the penalty shall be penalized only once for documents relating to the same taxpayer for a single tax period or event.
  • § 301.6707 Material Advisor Penalty for Failure to Furnish Information Regarding Reportable Transactions
  • § 301.6707A Failure to include on any return or statement any information required to be disclosed under section 6011 with respect to a reportable transaction.
  • § 301.6708 Failure to Maintain List of Advisees With Respect to Reportable Transactions
  • § 301.6662A Imposition of accuracy-related penalty on understatements with respect to reportable transactions