§53.4965-3. Prohibited tax shelter transactions.
26 C.F.R. § 53.4965-3
Listed transactions within the meaning of section 6707A(c)(2), including subsequently listed transactions described in paragraph (b) of this section; and
Prohibited reportable transactions, which consist of the following reportable transactions within the meaning of section 6707A(c)(1)—
Confidential transactions, as described in § 1.6011-4(b)(3) of this chapter; or
Transactions with contractual protection, as described in § 1.6011-4(b)(4) of this chapter.
Subsequently listed transactions. A subsequently listed transaction for purposes of section 4965 is a transaction that is identified by the Secretary as a listed transaction after the tax-exempt entity has entered into the transaction and that was not a prohibited reportable transaction (within the meaning of section 4965(e)(1)(C) and paragraph (a)(2) of this section) at the time the entity entered into the transaction.
Cross-reference. The determination of whether a transaction is a listed transaction or a prohibited reportable transaction for section 4965 purposes shall be made under the law applicable to section 6707A(c)(1) and (c)(2).
Effective/applicability dates. See § 53.4965-9 for the discussion of the relevant effective and applicability dates.
Notes, amendments, and revision history
Amendments
[T.D. 9492, 75 FR 38702, July 6, 2010]
Source
Source: T.D. 8084, 51 FR 16303, May 2, 1986, unless otherwise noted.
Authority
Authority: 26 U.S.C. 7805; 4960, unless otherwise noted. Section 53.6011-1 also issued under 26 U.S.C. 6011; Section 53.6060-1 also issued under 26 U.S.C. 6060(a); Section 53.6081-1 also issued under 26 U.S.C. 6081(a); Section 53.6109-1 also issued under 26 U.S.C. 6109(a); Section 53.6109-2 also issued under 26 U.S.C. 6109(a); Section 53.6695-1 also issued under 26 U.S.C. 6695(b).
Amendments
[T.D. 9492, 75 FR 38702, July 6, 2010]