26 U.S.C. § 6111: Disclosure of reportable transactions

information identifying and describing the transaction, information describing any potential tax benefits expected to result from the transaction, and such other information as the Secretary may prescribe. who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and who directly or indirectly derives gross income in excess of the threshold amount (or such other amount as may be prescribed by the Secretary) for such aid, assistance, or advice. $50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and $250,000 in any other case. The term “reportable transaction” has the meaning given to such term by section 6707A(c). that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements, exemptions from the requirements of this section, and such rules as may be necessary or appropriate to carry out the purposes of this section. Except as provided in paragraph (2), the amendments made by this section [amending this section and sections 6662 and 6707 of this title] shall apply to any tax shelter (as defined in section 6111(d) of the Internal Revenue Code of 1986, as amended by this section) interests in which are offered to potential participants after the Secretary of the Treasury prescribes guidance with respect to meeting requirements added by such amendments. The amendments made by subsection (c) [amending section 6662 of this title ] shall apply to items with respect to transactions entered into after the date of the enactment of this Act [ Aug. 5, 1997 ].” The amendments made by this section [enacting this section and section 6707 of this title and renumbering former section 6111 as section 6112 of this title ] shall apply to any tax shelter (within the meaning of section 6111 of the Internal Revenue Code of 1986 [formerly I.R.C. 1954], as added by this section) any interest in which is first sold to any investor after August 31, 1984 . For purposes of determining whether any investment is a tax shelter by reason of section 6111(c)(1)(B)(iii) of such Code (as added by this section), only offers for sale after August 31, 1984 , shall be taken into account. With respect to interests sold before September 1, 1984 , any liability to act under paragraph (1) of section 6111(b) of such Code (as added by this section) which would (but for this sentence) arise before such date shall be deemed to arise on December 31, 1984 .”