Proposed IRS Regulations Relating to the Reporting of Patented Transactions
Published on:
January 31, 2008
SIFMA provides comments to the Internal Revenue Service (IRS) on proposed regulations relating to the reporting of patented transactions, REG-129916-07. The proposal would add a “patented transactions” category of reportable transactions and require participants and material advisors in patented transactions to report the transactions to the IRS. SIFMA offers broad and specific recommendations to improve provisions of the proposal including: (1) transactions patented primarily for nontax reasons; (2) patented transactions that are not tax avoidance transactions; (3) the definition of “tax planning method;” (4) the definition of “fee;” and (5) interaction between “participant” and “patented transaction” rules.