Taxpayers who fail to disclose their participation in the transactions may be subject to penalties, as are advisors who fail to disclose or maintain and furnish the information to the IRS.
The new transactions include ones in which a U.S. taxpayer that owns controlled foreign corporations that hold stock of a lower-tier CFC through a domestic partnership takes the position that Subpart F income of the lower-tier CFC or an amount determined under Section 956(a) related to holdings of U.S. property by the lower-tier CFC does not result in income inclusions for the U.S. taxpayer.
For further updates to the lists, visit www.irs.gov/businesses/corporations and click on Abusive Tax Shelters and Transactions.
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