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

How the election may affect taxation of business income

This report summarizes recent proposals to reform the U.S. business income tax system and considers the path to enactment of any such legislation.

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

Did you follow 2016’s biggest accounting news?

CPAs will remember 2016 as a year of new standards and new faces. How well did you follow the biggest accounting events? The 7 questions in this quiz will help you find out