26 C.F.R. § 301.6111-2 Confidential Corporate Tax Shelters
Library | Code of Federal Regulations |
Edition | 2023 |
Currency | Current through December 31, 2023 |
Citation | 26 C.F.R. § 301.6111-2 |
Year | 2023 |
(a)
-
(1) Under section 6111(d)
and this section, a confidential corporate tax shelter is treated as a tax
shelter subject to the requirements of sections 6111 (a) and (b).
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(2) A confidential corporate tax shelter is
any transaction-
-
(3)
For purposes of this section, references to the term
-
(4) A transaction described in paragraph (b)
of this section is for a direct or an indirect corporate participant if it is
expected to provide Federal income tax benefits to any corporation (U.S. or
foreign) whether or not that corporation participates directly in the
transaction.
(b)
-
(1)
-
(2)
-
(3)
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