Tax Patents Reportable Transactions


The IRS and Treasury Department issued proposed regulations that add patented transactions to Treas. Reg. § 1.6011-4 on reportable transactions. REG-129916-07 also makes conforming changes to IRC section 6111 on disclosure of reportable transactions by material advisers. Comments and public hearing requests are due by Dec. 26. The AICPA and others have sought a legislative solution to what they say are problems caused by patents granted for tax strategies (see “ Tax Patents Considered ,” JofA , July 07, page 40, and “Washington Report ,” this issue, page 27). At their urging, the House of Representatives included a prohibition of tax strategy patents in a patent reform bill that passed that chamber in early September. However, the Institute and others have advised against classifying patented transactions as reportable transactions for all taxpayers, after the IRS and Treasury floated the idea last November in a preamble to other proposed regulations.

SPONSORED REPORT

Revenue recognition: A complex effort

Implementing the new standard requires careful judgment. Learn how to make significant accounting judgments and document them and collaborate with peers for consistent application.

VIDEO

How to Excel pivot a general ledger

The general ledger is a vast historical data archive of your company's financial activities, including revenue, expenses, adjustments, and account balances. J. Carlton Collins, CPA, shows how to prepare data for, and mine data with, PivotTables.

QUIZ

News quiz: Taking an economic snapshot and looking to the future

Recent news included IRS actions that affect individuals and partnerships and a possibly influential move by a Big Four accounting firm.Take this short quiz to see how much you know about the news.