Friday, July 16, 2010

Final Regulations Regarding Excise Taxes on Prohibited Tax Shelter Transactions

Final Regulations Regarding Excise Taxes on Prohibited Tax Shelter Transactions: "RS and Treasury Issue Final Regulations Regarding Excise Taxes on Prohibited Tax Shelter Transactions and Related Disclosure Requirement

July 2010

The following discussion is provided for informational purposes only and is not intended to serve as legal or tax advice. For specific information about prohibited tax shelter transactions, consult your attorney or tax advisor.

Reprinted from Exempt Organizations Advisory

[On July 2, 2010], the IRS and Treasury issued final regulations under section 4965 and section 6011(g) relating to entity-level and manager-level excise taxes with respect to prohibited tax shelter transactions to which tax-exempt entities are parties. The final regulations replace proposed regulations that were issued in 2007. The IRS and Treasury also issued final regulations under sections 6011, 6033, and 6071 relating to certain disclosure and return filing obligations with respect to such transactions. The final regulations replace temporary regulations that were issued in 2007. In both cases, the final regulations adopt the earlier regulations with certain minor modifications."

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