The Treasury Department and IRS today released for publication in the Federal Register proposed regulations (REG-103033-11) as guidance concerning the amount of the penalty imposed under section 6707A for a failure to include, on any return or statement, any information required to be disclosed under section 6011 relating to reportable transactions.
Section 6707A imposes a penalty on a taxpayer who has a duty to disclose a reportable transaction and fails to do so, and also requires certain taxpayers to disclose to the Securities and Exchange Commission (SEC) a requirement to pay a penalty relating to listed transactions or undisclosed reportable transactions.
According to the preamble, the proposed regulations are necessary to clarify the amount of the penalty under section 6707A, as amended by the Small Business Jobs Act of 2010, Pub. L. No. 111-240.
The proposed regulations [PDF 243 KB] include provisions that:
Comments and requests for a public hearing on the proposed regulations must be received by a date that is 90 days after August 28, 2015 (the date when these regulations will be published in the Federal Register).
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