(1) a written statement from one of the tax hosting agencies stating that the promoter has registered the tax accommodation in accordance with this section; and (iv) discussion. The discussion of participation in a transaction involves a discussion of such participation with anyone who transmits the proposal of the promoter of the tax shield. For the purposes of this paragraph, g) (2), anyone directly or indirectly involved in a transaction is treated as if they had discussed participation in the transaction by the time of the participation agreement. Thus, a participant in the tax hosting is treated as if he had discussed participation in the transaction, even if all the interviews were conducted through an intermediary and the participation agreement was concluded indirectly through another person acting on behalf of the participant (for example. B by an intermediary authorized to compel the participant to participate in the pound). (f) definition of the tax accommodation institution. For the purposes of Section 6111 (d) (2) and this section, the concept of a tax protection agency includes a tax protection agency and any other person involved in the organization: 301.6111-1T (Q-A-26 by Q-A-26) 33) or anyone connected with such a tax operator or other person (in the sense of section 267 or 707). (ii) that any potential participant is under the terms of the confidentiality outlined in this section; and (1) tax protection promoters. The rules of Sections 6111 (a) and (e) and 301.6111-1T (Q-A-34 to Q-A-39) determine who should register a confidential corporate tax unit. A developer of a confidential tax dwelling may only register tax accommodation if it is a person who must register in accordance with sections 6111 a) and (e) and 301.6111-1T (Q-A-34 to Q-A-39).
Ministry of Finance rules require that certain tax housing and transactions be registered and that investor lists be maintained by parties who organize or sell interest in accommodation. Investors in certain institutions and transactions are required to disclose their participation in their tax returns. (A) discusses participation in tax accommodation with a promoter who is a person in the United States; Or the IRS manages an abusive tax emergency number that people can use to provide information (anonymous, if privileged) about abusive tax protection transactions. The Office of Tax Shelter Analysis is primarily interested in potentially abusive transactions that can be used by many taxpayers and could pose a significant risk to IRS compliance. (2) Listed transactions. A transaction is described in point b) (2) where the transaction is identical to one of the types of transactions or is essentially a type of transaction that the Internal Revenue Service (IRS) has classified as a tax evasion transaction and which, by notification, regulation or any other form of published guidance, has been identified as a publicly traded transaction. When a transaction becomes a listed transaction after the date on which registration in this section is required, and the transaction also meets the confidentiality and royalty requirements set out in paragraphs (a) (2) (ii) and (iii) of this section, it is in any event necessary to register for all shares of the transaction that will be put up for sale after the transaction. However, since a transaction identified as a listed transaction is generally considered structured for significant tax evasion purposes, such a transaction is normally recorded in accordance with this section, before becoming a listed transaction, if the transaction pre-fulfilled the confidentiality and pricing requirements set out in paragraphs (a) (2) and (iii) of this section. (3) Presumption. Unless otherwise stated, an offer is not accepted under conditions of confidentiality if the promoter of the tax hosting project grants each bidder (and any employee, representative or other representative of such a supplier) express written permission to ensure tax treatment to any person, without restriction of any kind.