Code of Federal Regulations (Last Updated: November 8, 2024) |
Title 26 - Internal Revenue |
Chapter I - Internal Revenue Service, Department of the Treasury |
SubChapter F - Procedure and Administration |
Part 301 - Procedure and Administration |
SubPart - Information and Returns |
Records, Statements, and Special Returns |
§ 301.6111-3T - Disclosure of reportable transactions (temporary).
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(a) through (g) [Reserved]
(h)
Rulings. If a potential material advisor requests a ruling as to whether a specific transaction is a reportable transaction on or before the date that disclosure would otherwise be required under this section, the Commissioner in his discretion may determine thatthe submission satisfies the disclosure rules under this section for that transaction if the request fully discloses all relevant facts relating to the transaction which would otherwise be required to be disclosed under this section. The potential obligation of the person to disclose the transaction under this section (or to maintain or furnish the list under § 301.6112-1) will not be suspended during the period that the ruling request is pending. (i)
Effective date —(1) [Reserved](2)
Tolling provision. Paragraph (h) of this section applies to ruling requests received on or after November 1, 2006. The applicability of this section expires on or before November 2, 2009.