§ 6111. Disclosure of reportable transactions

• (a) Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth—
  • (1) information identifying and describing the transaction,
  • (2) information describing any potential tax benefits expected to result from the transaction, and
  • (3) such other information as the Secretary may prescribe.
• (b) For purposes of this section:
  • (1)
    • (A) The term “material advisor” means any person—
      • (i) who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and
      • (ii) 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.
    • (B) For purposes of subparagraph (A), the threshold amount is—
      • (i) $50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and
      • (ii) $250,000 in any other case.
  • (2) The term “reportable transaction” has the meaning given to such term by section 6707A(c).
• (c) The Secretary may prescribe regulations which provide—
  • (1) 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,
  • (2) exemptions from the requirements of this section, and
  • (3) such rules as may be necessary or appropriate to carry out the purposes of this section.