Reportable Transactions (Portfolio 648)


Jeffrey H Paravano




Todd Simmens

National Managing Partner of Tax Risk Management


At a glance

I. Background
II. Overview of Reportable Transaction Categories
III. Listed Transactions
IV. Transactions with Contractual Protection
V. Confidential Transactions
VI. Section 165 Losses
VII. Transactions of Interest
VIII. Brief Asset Holding Period Transactions (Removed)
IX. Significant Book-Tax Difference (Removed)
X. Patented Tax Transactions (Proposed)
XI. Compliance Procedures
XII. Protective Disclosures
XIII. Penalties Related to Reportable Transactions
XIV. Private Letter Ruling Requests
XV. Exceptions for Regulated Investment Companies and Leasing Transactions
XVI. Record Retention
XVII. Section 6111/6112-Reporting and List Maintenance by Material Advisors
XVIII. State Reportable Transaction Overview


Bloomberg Tax Portfolio, Reportable Transactions, No. 648, provides an in-depth discussion of the reportable transaction rules under Regs. §1.6011-4 as well as the associated penalties for noncompliance. The Portfolio begins with a historical look at the developments leading to the introduction of the first reportable transaction regime in 2000. The Portfolio then provides a detailed analysis of the rules under the reportable transaction rules as they existed in 2000 and, more specifically, an in-depth discussion of the rules as finally adopted and amended in 2003 and 2007, as well as the penalties for non-compliance. The Portfolio then discusses the “registration” and “list maintenance” rules under §§6111 and 6112 as they existed both before and after the enactment of the American Jobs Creation Act of 2004, as well as the penalties for non-compliance. Finally, the Portfolio provides an overview of the various states that have also enacted a reportable transaction regime.

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