Internal Revenue Code · 26 U.S.C.
§ 6111. Disclosure of reportable transactions
Official text, no changes From the Office of the Law Revision Counsel, release point 119-121 (current through Public Law 119-121 (October 9, 2026)). Compare it with the official text at uscode.house.gov (external site).
Cite as 26 U.S.C. § 6111
At a glance
Read from the text, the source credit and the official notes. Not part of the law.
- Status
- In force
- Added
- July 18, 1984 by Pub. L. 98–369
- Last amended
- December 21, 2005 by Pub. L. 109–135
- Amendments
- 4 dated changes in the source credit
- Length
- 3 subsections · 342 words · about 1 min to read
- Defines
- 2 terms
- Cross-references
- cites 1; cited by 3 Code sections and 8 other regulations
- Regulations
- 3 issued under this section
The term “reportable transaction” has the meaning given to such term by section 6707A(c).
(Added Pub. L. 98–369, div. A, title I, § 141(a), July 18, 1984, 98 Stat. 677; amended Pub. L. 99–514, title II, § 201(d)(13), title XV, § 1531(a), title XVIII, § 1899A(54), Oct. 22, 1986, 100 Stat. 2142, 2749, 2961; Pub. L. 105–34, title X, § 1028(a), Aug. 5, 1997, 111 Stat. 926; Pub. L. 108–357, title VIII, § 815(a), Oct. 22, 2004, 118 Stat. 1581; Pub. L. 109–135, title IV, § 412(zz), Dec. 21, 2005, 119 Stat. 2641.)
Terms defined here
Where the text says “the term … means”. Select a term to jump to its definition.
Regulations under this section
Treasury regulations (26 CFR) issued under § 6111
Cross-references
Computed from the citations in the text of Title 26 and 26 CFR.
This section cites 1 other section
Cited by 3 Code sections
- § 6112(a) Material advisors of reportable transactions must keep lists of advisees, etc.
- § 6664(d)(4)(B)(ii)(I) Definitions and special rules
- § 6707(a) Failure to furnish information regarding reportable transactions
Cited in 8 regulations not issued under it
- § 1.6011-9 Syndicated conservation easement listed transactions.
- § 1.6011-18 Certain partnership related-party basis adjustment transactions as transactions of interest.
- § 1.6664-2 Underpayment.
- § 53.4965-6 Meaning of “knows or has reason to know”.
- § 301.6112-1 Material advisors of reportable transactions must keep lists of advisees, etc.
- § 301.6501(c)-1 Exceptions to general period of limitations on assessment and collection.
- § 301.6707-1 Failure to furnish information regarding reportable transactions.
- § 301.6708-1 Failure to maintain lists of advisees with respect to reportable transactions.
Amendment history
From the source credit and the official notes, newest first.
- Amended by Pub. L. 109–135Parts changed in 2005: (b)(1)(A)(ii)
- Amended by Pub. L. 108–357
- Amended by Pub. L. 105–34Parts changed in 1997: (d)
- Amended by Pub. L. 99–514Parts changed in 1986: (c)(2)(A) (c)(3)(B)(ii) (d)(1)(B)
- Added by Pub. L. 98–369
Where it sits in the Code
- Subtitle F Procedure and Administration
- Chapter 61 INFORMATION AND RETURNS
- Subchapter B Miscellaneous Provisions
Nearby sections
- § 6107 Tax return preparer must furnish copy of return to taxpayer and must retain a copy or list
- § 6108 Statistical publications and studies
- § 6109 Identifying numbers
- § 6110 Public inspection of written determinations
- § 6111 Disclosure of reportable transactions
- § 6112 Material advisors of reportable transactions must keep lists of advisees, etc.
- § 6113 Disclosure of nondeductibility of contributions
- § 6114 Treaty-based return positions
- § 6115 Disclosure related to quid pro quo contributions
Official notes
Show the Law Revision Counsel's notes (amendments, effective dates)
Editorial Notes
Prior Provisions
A prior section 6111 was renumbered 6116 of this title.
Amendments
2005—Subsec. (b)(1)(A)(ii). Pub. L. 109–135 substituted “aid, assistance, or advice” for “advice or assistance”.
2004—Pub. L. 108–357 amended section catchline and text generally, substituting provisions relating to disclosure of reportable transactions for provisions relating to registration of tax shelters and inclusion of identification numbers on returns.
1997—Subsecs. (d) to (f). Pub. L. 105–34 added subsec. (d) and redesignated former subsecs. (d) and (e) as (e) and (f), respectively.
1986—Subsec. (c)(2)(A). Pub. L. 99–514, § 1531(a), substituted “350 percent” for “200 percent”.
Subsec. (c)(3)(B)(ii). Pub. L. 99–514, § 201(d)(13), substituted “section 465(b)(3)(C)” for “section 168(e)(4)”.
Subsec. (d)(1)(B). Pub. L. 99–514, § 1899A(54), substituted “subparagraph” for “subpargraph”.
Statutory Notes and Related Subsidiaries
Effective Date of 2004 Amendment
Pub. L. 108–357, title VIII, § 815(c), Oct. 22, 2004, 118 Stat. 1583, provided that: “The amendments made by this section [amending this section and sections 6112 and 6708 of this title] shall apply to transactions with respect to which material aid, assistance, or advice referred to in section 6111(b)(1)(A)(i) of the Internal Revenue Code of 1986 (as added by this section) is provided after the date of the enactment of this Act [Oct. 22, 2004].”
Effective Date of 1997 Amendment
Pub. L. 105–34, title X, § 1028(e), Aug. 5, 1997, 111 Stat. 928, provided that:
“(1) In general.— 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.“(2) Modifications to substantial understatement penalty.— 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].”
Effective Date of 1986 Amendment
Amendment by section 201(d)(13) of Pub. L. 99–514 applicable to property placed in service after Dec. 31, 1986, in taxable years ending after such date, with exceptions, see sections 203 and 204 of Pub. L. 99–514, set out as a note under section 168 of this title.
Amendment by section 201(d)(13) of Pub. L. 99–514 not applicable to any property placed in service before Jan. 1, 1994, if such property placed in service as part of specified rehabilitations, and not applicable to certain additional rehabilitations, see section 251(d)(2), (3) of Pub. L. 99–514, set out as a note under section 46 of this title.
Pub. L. 99–514, title XV, § 1531(b), Oct. 22, 1986, 100 Stat. 2749, provided that: “The amendment made by this section [amending this section] 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 amended by this section) interests in which are first offered for sale after December 31, 1986.”
Effective Date
Pub. L. 98–369, div. A, title I, § 141(d), July 18, 1984, 98 Stat. 680, as amended by Pub. L. 99–514, § 2, Oct. 22, 1986, 100 Stat. 2095, provided that:
“(1) In general.— 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.“(2) Substantial investment test.— 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.“(3) Furnishing of shelter identification number for interests sold before september 1, 1984.— 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.”