The Internal Revenue Service has expanded its lists of “transactions of interest” and “listed transactions” that taxpayers must disclose if they are participating in any of them.

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 and click on “Abusive Tax Shelters and Transactions.”

Register or login for access to this item and much more

All Accounting Today content is archived after seven days.

Community members receive:
  • All recent and archived articles
  • Conference offers and updates
  • A full menu of enewsletter options
  • Web seminars, white papers, ebooks

Don't have an account? Register for Free Unlimited Access