AJCA modifications to disclosure of reportable transactions and list maintenance requirements
Reportable transaction disclosure statements
Material advisor disclosure statements
- Final regulations under Section 6111
- Final regulations under Section 6112
- Form 8918, Material Advisor Statement PDF
Penalties associated with reportable transactions
- Promoting Abusive Tax Shelters. The penalty is for a promoter of an abusive tax shelter and is generally equal to $1,000 for each organization or sale of an abusive plan or arrangement (or, if lesser, 100 percent of the income derived from the activity).
- Penalties for aiding and abetting understatement of tax liability. The penalty is $1000 ($10,000 if the conduct relates to a corporation’s tax return) for aiding and abetting in an understatement of a tax liability. Any person subject to the penalty shall be penalized only once for documents relating to the same taxpayer for a single tax period or event.
- Material Advisor Penalty for Failure to Furnish Information Regarding Reportable Transactions
- Failure to include on any return or statement any information required to be disclosed under section 6011 with respect to a reportable transaction.
- Failure to Maintain List of Advisees With Respect to Reportable Transactions
- Imposition of accuracy-related penalty on understatements with respect to reportable transactions