November 2006 Proposed Tax Regulations on 'Reportable Transactions'

On November 2, 2006, the New York office authored an Alert Memorandum entitled “November 2006 Proposed Tax Regulations on ’Reportable Transactions’.” The alert discusses a package of proposed regulations released by the Internal Revenue Service on November 1, 2006. The proposed regulations update and modify the taxpayer disclosure, material advisor listing and material advisor disclosure rules relating to certain “reportable transactions.” Among other matters, the proposed regulations propose to add a new category of reportable transactions for “transactions of interest,” and generally would treat persons providing insurance for the tax benefits of reportable transactions as material advisors subject to list-keeping and disclosure requirements. The alert summarizes the principal provisions of these proposed regulations.