New Analysis Removes Doubt Concerning Reportable Transaction Disclosures

ARLINGTON, Va., Dec. 8, 2010 /PRNewswire-USNewswire/ -- Throughout the last decade, in response to increasing concern over the use of abusive tax shelters, the Treasury began implementation of its taxpayer disclosure regime.  The enactment of the American Jobs Creation Act, however, provided serious consequences for failure to disclose in terms of penalties and extended assessment periods for additional taxes.  BNA's latest analysis, Reportable Transactions, examines the evolution of the reportable transactions rules, provides an in-depth discussion of the current rules under Regs. Section 1.6011-4, and details the penalties for non-compliance.

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Number 648 in BNA's Tax Management Series, Reportable Transactions reviews the original reportable transaction rules, introduced in 2000, and analyzes the rules as they were modified and reissued in 2003 and 2007.  In addition, the Portfolio examines the pre- and post-American Jobs Creation Act of 2004 "registration" and "list maintenance" rules under Sections 6111 and 6112.

"Although the current Form 8886, Reportable Transaction Disclosure Statement leaves little to taxpayer discretion or interpretation, a complete disclosure of a 'reportable transaction' still requires a thorough and knowledgeable approach," says Karen Fickes, Managing Editor with BNA Tax & Accounting.  "The penalties are too high to risk making mistakes."

Authors Todd C. Simmens, CPA, Esq., and James G. Hartford, Esq., review seven categories of reportable transactions — two of them discontinued — and the proposed patented tax transactions rules.  They walk taxpayers and material advisors through the compliance process and discuss four classes of penalties associated with reportable transactions, including exceptions for regulated investment companies and leasing transactions.

Reportable Transactions includes an overview of the states that have also enacted a reportable transaction regime, a chart showing the timing and effective dates of the various reportable transaction regulations, and a chart listing selected relevant IRS reportable transaction guidance.

Todd C. Simmens, CPA, Esq., is a partner and the National Director of Tax Controversy and Procedure with BDO Seidman, LLP, in Woodbridge, New Jersey.  He previously served as Legislation Counsel to the U.S. Congress, Joint Committee on Taxation, and Attorney-Advisor to the Honorable Joel Gerber, U.S. Tax Court, in Washington, D.C.  Simmens chairs the Legislation Subcommittee and the Court Procedure Committee of the American Bar Association Tax Section, and speaks frequently on a variety of federal tax issues.

James G. Hartford, Esq., is an attorney with the IRS Office of Chief Counsel (Procedure & Administration) in Washington, D.C.  He is a member of the American Bar Association Tax Section, a former vice-chair of the American Bar Association's Administrative Practice Committee, a frequent speaker and commentator on IRS administrative procedure/litigation topics, and the co-author of articles on IRS practice and procedure issues.

About BNA Tax & Accounting

BNA Tax & Accounting is the foremost source of news, analysis, and practice tools for tax attorneys, estate planners, accountants, and corporate tax and financial accounting professionals. For more than 50 years, BNA Tax & Accounting has offered practitioners expert insights and guidance on every significant issue in tax planning and financial accounting. Written by practitioners for practitioners, BNA's award-winning Portfolios offer topic-driven, in-depth guidance on transactions designed to help tax professionals achieve new levels of excellence and client service. For more information on BNA's Federal Tax series of which this Portfolio is a part, go to http://www.bnatax.com/federal-tax-t555/ or call 800.372.1033.

SOURCE BNA Tax & Accounting

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