Prop. Treas. Reg. § 301.6111-3 Disclosures of reportable transactions.

Proposed 2007-09-26 · REG-103038-05 · 72 FR 54615 · Interprets § 6111 · Would amend § 301.6111-3

Par. 4. Section 301.6111-3 is amended by revising paragraphs (b)(2)(ii)(E), (b)(3)(i)(C), and (i)(2) to read as follows:

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(b) * * *

(2) * * *

(ii) * * *

(E) Patented transactions . A statement relates to a tax aspect of a transaction that causes it to be a patented transaction if the statement is made or provided by the patent holder or by the patent holder's agent, as defined in § 1.6011-4(b)(7)(ii)(C) or (D) of this chapter, and concerns the tax planning method that is the subject of the patent.

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(3) * * *

(i) * * *

(C) Patented transactions. For patented transactions described in § 1.6011-4(b)(7) of this chapter, the threshold amounts in § 301.6111-3(b)(3)(i)(A) are reduced from $50,000 to $250 and from $250,000 to $500.

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(i) * * *

(2) Patented transactions. Upon the publication of the Treasury decision adopting these rules as final regulations in the Federal Register , paragraphs (b)(2)(ii)(E) and (b)(3)(i)(C) of this section will apply to transactions with respect to which a material advisor makes a tax statement on or after September 26, 2007.