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This document contains final regulations that identify transactions that are the same as, or substantially similar to, certain micro-captive transactions as listed transactions, a type of reportable transaction, and certain other micro-captive transactions as transactions of interest, another type of reportable transaction. Material advisors and certain participants in these listed transactions and transactions of interest are required to file disclosures with the IRS and are subject to penalties for failure to disclose. The final regulations affect participants in these transactions as well as material advisors.
Published
Jan 14, 2025
Effective
Jan 14, 2025
Citation
90 FR 3534
Agencies
2
Full text not available in our database.
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TD 10029
1545-BQ44
26 CFR 1