republic-os/legal/us/code/title-26/chapter-61/section-6111.md

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LegalText	26 U.S.C. § 6111	Disclosure of reportable transactions	us	united_states_code	code_section	26	INTERNAL REVENUE CODE	61	INFORMATION AND RETURNS	6111	26 U.S.C. § 6111	current	119-100	2026-06-26	official	https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip	/us/usc/t26/s6111	data/legal/raw/us/code/title-26/usc26.xml	b9320b292864596ef5cdb6b323773824ebe68366b9348789f39392763da457c3	a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4	286de2ce46c7079e30e5787ed2f56a1c60ab80eacf96f4e772347bd870456e61	2026-07-04	official	legal us-code

26 U.S.C. § 6111 - Disclosure of reportable transactions

Text

(a) In general Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth—

(1) information identifying and describing the transaction,

(2) information describing any potential tax benefits expected to result from the transaction, and

(3) such other information as the Secretary may prescribe.

Such return shall be filed not later than the date specified by the Secretary.

(b) Definitions For purposes of this section:

(1) Material advisor (A) In general The term “material advisor” means any person—

(i) who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and

(ii) who directly or indirectly derives gross income in excess of the threshold amount (or such other amount as may be prescribed by the Secretary) for such aid, assistance, or advice.

(B) Threshold amount For purposes of subparagraph (A), the threshold amount is—

(i) $50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and

(ii) $250,000 in any other case.

(2) Reportable transaction The term “reportable transaction” has the meaning given to such term by section 6707A(c).

(c) Regulations The Secretary may prescribe regulations which provide—

(1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements,

(2) exemptions from the requirements of this section, and

(3) such rules as may be necessary or appropriate to carry out the purposes of this section.

(Added Pub. L. 98–369, div. A, title I, § 141(a), July 18, 1984, 98 Stat. 677; amended Pub. L. 99–514, title II, § 201(d)(13), title XV, § 1531(a), title XVIII, § 1899A(54), Oct. 22, 1986, 100 Stat. 2142, 2749, 2961; Pub. L. 105–34, title X, § 1028(a), Aug. 5, 1997, 111 Stat. 926; Pub. L. 108–357, title VIII, § 815(a), Oct. 22, 2004, 118 Stat. 1581; Pub. L. 109–135, title IV, § 412(zz), Dec. 21, 2005, 119 Stat. 2641.)

Notes

Editorial Notes

Prior ProvisionsA prior section 6111 was renumbered 6116 of this title.

Amendments2005—Subsec. (b)(1)(A)(ii). Pub. L. 109–135 substituted “aid, assistance, or advice” for “advice or assistance”. 2004—Pub. L. 108–357 amended section catchline and text generally, substituting provisions relating to disclosure of reportable transactions for provisions relating to registration of tax shelters and inclusion of identification numbers on returns. 1997—Subsecs. (d) to (f). Pub. L. 105–34 added subsec. (d) and redesignated former subsecs. (d) and (e) as (e) and (f), respectively. 1986—Subsec. (c)(2)(A). Pub. L. 99–514, § 1531(a), substituted “350 percent” for “200 percent”. Subsec. (c)(3)(B)(ii). Pub. L. 99–514, § 201(d)(13), substituted “section 465(b)(3)(C)” for “section 168(e)(4)”. Subsec. (d)(1)(B). Pub. L. 99–514, § 1899A(54), substituted “subparagraph” for “subpargraph”.

Statutory Notes and Related Subsidiaries

Effective Date of 2004 AmendmentPub. L. 108–357, title VIII, § 815(c), Oct. 22, 2004, 118 Stat. 1583, provided that: “The amendments made by this section [amending this section and sections 6112 and 6708 of this title] shall apply to transactions with respect to which material aid, assistance, or advice referred to in section 6111(b)(1)(A)(i) of the Internal Revenue Code of 1986 (as added by this section) is provided after the date of the enactment of this Act [Oct. 22, 2004].”

Effective Date of 1997 AmendmentPub. L. 105–34, title X, § 1028(e), Aug. 5, 1997, 111 Stat. 928, provided that: “(1) In general.—Except as provided in paragraph (2), the amendments made by this section [amending this section and sections 6662 and 6707 of this title] shall apply to any tax shelter (as defined in section 6111(d) of the Internal Revenue Code of 1986, as amended by this section) interests in which are offered to potential participants after the Secretary of the Treasury prescribes guidance with respect to meeting requirements added by such amendments. “(2) Modifications to substantial understatement penalty.—The amendments made by subsection (c) [amending section 6662 of this title] shall apply to items with respect to transactions entered into after the date of the enactment of this Act [Aug. 5, 1997].”

Effective Date of 1986 AmendmentAmendment by section 201(d)(13) of Pub. L. 99–514 applicable to property placed in service after Dec. 31, 1986, in taxable years ending after such date, with exceptions, see sections 203 and 204 of Pub. L. 99–514, set out as a note under section 168 of this title. Amendment by section 201(d)(13) of Pub. L. 99–514 not applicable to any property placed in service before Jan. 1, 1994, if such property placed in service as part of specified rehabilitations, and not applicable to certain additional rehabilitations, see section 251(d)(2), (3) of Pub. L. 99–514, set out as a note under section 46 of this title. Pub. L. 99–514, title XV, § 1531(b), Oct. 22, 1986, 100 Stat. 2749, provided that: “The amendment made by this section [amending this section] shall apply to any tax shelter (within the meaning of section 6111 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954] as amended by this section) interests in which are first offered for sale after December 31, 1986.”

Effective DatePub. L. 98–369, div. A, title I, § 141(d), July 18, 1984, 98 Stat. 680, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that: “(1) In general.—The amendments made by this section [enacting this section and section 6707 of this title and renumbering former section 6111 as section 6112 of this title] shall apply to any tax shelter (within the meaning of section 6111 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954], as added by this section) any interest in which is first sold to any investor after August 31, 1984. “(2) Substantial investment test.—For purposes of determining whether any investment is a tax shelter by reason of section 6111(c)(1)(B)(iii) of such Code (as added by this section), only offers for sale after August 31, 1984, shall be taken into account. “(3) Furnishing of shelter identification number for interests sold before september 1, 1984.—With respect to interests sold before September 1, 1984, any liability to act under paragraph (1) of section 6111(b) of such Code (as added by this section) which would (but for this sentence) arise before such date shall be deemed to arise on December 31, 1984.”