Tax Shelter Confidentiality Agreements

(iii) identification of foreign status. For the purposes of this subsection (g) (2), a person must consider all the beneficiaries of the tax to be foreign persons, unless the person is – (d) the setting of the royalties. All facts and circumstances related to the transaction are taken into account as a whole in determining the amount of fees that proponents can collect. For the purposes of this paragraph (d), account shall be taken of all consideration that may be received by tax relief proponents, including contingency charges, equity fees and royalties that project proponents may receive for other transactions in return for promoting the tax reduction. (A) The person does not participate directly or indirectly in the accommodation and informs the tax agency in writing, within 90 days of the start of these interviews, that the person will not participate; or the Office of Tax Shelter Analysis (OTSA) of the Large Business & International Division (LB&I) collects and analyzes information on abusive tax practices and transactions and coordinates the planning and operation of LB&I. We are taking steps to combat tax havens and abusive transactions. There is an overall strategy for: (5) decision requests. If a tax agency (or any other person responsible for registration under this Section) is not sure whether a transaction is properly classified as a confidential corporate tax auxiliary or whether there is no further doubt as to the need for registration under this Section, that person may, on or before the date on which registration would otherwise be required under this Section: to apply to the IRS to determine whether the transaction is subject to the registration requirements of this Section. .

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