Instructions For Form 8886 - Reportable Transaction Disclosure Statement Page 6
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7numbers) are issued to material
the same or substantially similar. See
adjustments) to the basis of property,
advisors who file a statement disclosing
Substantially
Similar, earlier.
status as an entity exempt from federal
a reportable transaction under section
income taxation, and any other tax
Line 5
6111. Material advisors are required to
consequences that may reduce a
provide this number to investors/
taxpayer's federal income tax liability by
If you participated in the transaction
advisees.
affecting the amount, timing, character,
through other entities, indicate whether
or source of any item of income, gain,
each entity is a partnership, S
Line 2
expense, loss, or credit. Check the
corporation, or trust. In addition, if the
“Other” box for tax benefits not
Check the box(es) for all categories that
entity is foreign, check the box for
specifically identified by a box and
apply to the transaction being reported.
“Foreign.” On line 5b, provide the full
identify the tax benefits in the space
The reportable transaction categories
name of the entity. On line 5c, enter the
provided (for example, status as an
are described under
Participation in a
entity's EIN (if known). Use hyphens
entity exempt from federal income
Reportable
Transaction, earlier.
when entering the EIN. On line 5d, enter
taxation). If you need more space,
the date you received the Schedule K-1
follow the instructions under
How To
Note. The category for significant
from the entity. Enter “none” if
Complete Form
8886, earlier.
book-tax difference transactions has
Schedule K-1 was not received. If you
been eliminated by Notice 2006-6.
are reporting more than one entity, use
Line 7b
Transactions with a significant book-tax
a separate column for each entity.
difference that would have been
Attach additional sheets for more than
Describe the reportable transaction you
required to be disclosed after January 5,
two entities.
entered into and the relevant facts and
2006, are no longer reportable
tax benefits for all affected years that
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transactions.
caused the transaction to be reportable.
Describe each step of the transaction
However, if the transaction is also a
Enter the name, address, and social
including all information known to you.
transaction described in any of the
security number (SSN) or EIN (if known)
Include in your description other parties
remaining reportable transaction
for each individual or entity to whom you
to the transaction and, if known,
categories, it must still be disclosed and
paid a fee with regard to the transaction
assumptions of liabilities or other
the box for all appropriate categories
if that individual or entity promoted,
obligations, satisfaction of liabilities or
(that is, a, b, c, d, or e) must be
solicited, or recommended your
obligations, sales of property or
checked.
participation in the transaction, or
interests in property, the formation and
provided tax advice related to the
For more details, see Notice 2006-6.
dissolution of entities, and any
transaction. Also, enter the approximate
agreements between or among parties
Note. The category for brief asset
fees paid to each of the individuals or
to the transaction. Also describe any tax
holding period has been eliminated for
entities. These fees include payment in
result protection with respect to the
transactions entered into on or after
whatever form, whether in cash or in
transaction. The term “tax result
August 3, 2007. However, this does not
kind, for a tax strategy or for advice
protection” includes insurance company
relieve taxpayers of any disclosure
(whether or not tax advice). Fees also
and other third-party products
obligations for brief asset holding
include consideration for services to:
commonly described as tax result
transactions that were entered into
Analyze the transaction (whether or
insurance. Include, if known, the
before August 3, 2007. The rules for
not related to the tax consequences of
relevant dates and the amounts
brief asset holding period reportable
the transaction),
involved in the steps described.
transactions entered into before August
Implement the transaction,
Amounts involved include cash, fair
3, 2007, are contained in Regulations
Document the transaction, or
market value of property or services
section 1.6011-4 in effect prior to
Prepare tax returns to the extent the
transferred or acquired, adjustments to
August 3, 2007.
return preparation fees are
basis, valuation of notes, obligations,
unreasonable.
If the transaction is a listed
shares, or other securities. Describe, if
transaction or transaction of
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known, the relationship between the
You are also treated as paying fees
interest, you must check the
steps of the transaction and how each
to an advisor if you know or should
CAUTION
listed transaction box or transaction of
step relates to why the transaction is
know that an amount you paid will be
interest box in addition to any others
reportable. Your description should
paid indirectly to the advisor, such as
that may apply.
include the relevance, if known, of any
through a referral fee or fee-sharing
party (including but not limited to
arrangement. A fee does not include
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participants in the transaction) listed in
amounts paid to a person, including an
line 8.
advisor, in that person's capacity as a
Identify the notice, revenue ruling,
party to the transaction.
regulation, announcement, or other
Describe the economic and business
published guidance that identified the
Line 7a
reasons for the transaction and its
transaction as a listed transaction or a
structure. Describe market or business
Please check the box representing the
transaction of interest. For listed
conditions creating the tax benefit(s) or
type of tax benefit the transaction will
transactions, identify the guidance as
consequence(s) and the transaction's
reflect on your tax return. There may be
shown in Notice 2009-59, or later IRS
financial reporting, if known.
more than one tax benefit to your
guidance.
transaction. A tax benefit includes but is
If you checked box 2b, explain how
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not limited to the following: deductions,
your disclosure of information
exclusions from gross income,
concerning the transaction was limited
Do not report more than one transaction
nonrecognition of gain, tax credits,
(for example, by contract or verbal
on this form unless the transactions are
adjustments (or absence of
agreement) and the nature and extent of
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Instructions for Form 8886 (Rev. 8-2017)
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