AJCA penalties for noncompliance with reportable transaction regs.
The Tax Adviser › Vol. 36 Nbr. 4, April 2005
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Summary
American Jobs Creation Act of 2004
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AJCA penalties for noncompliance with reportable transaction regs.
On Oct. 22, 2004, President Bush signed into law the American Jobs Creation Act of 2004 (AJCA), a $138 billion tax package with a wide-ranging effect on foreign and domestic tax planning. Besides the AJCA's numerous tax planning opportunities, it alerts taxpayers to their obligation to disclose certain transactions the IRS deems reportable transactions. Prior to the AJCA, Regs. Sec. 1.6011-4, which required all taxpayers to disclose certain transactions that fell into one of six broad categories, prescribed no penalties for failing to disclose a "reportable transaction"
The AJCA added and modified numerous provisions to the reportable transaction roles. First, it imposed significant penalties for failing to ...See the full content of this document
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