§4965. Excise tax on certain tax-exempt entities entering into prohibited tax shelter transactions — Inbound Citations
26 U.S.C. § 4965
Cited by 9 provisions in release 119-102.
Citations to 26 U.S.C. § 4965 as a whole
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(C) Any term used in this section which is also used in section 4965 shall have the meaning given such term under section 4965.
Citations to §4965(c)
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(g) Any taxable party to a prohibited tax shelter transaction (as defined in section 4965(e)(1)) shall by statement disclose to any tax-exempt entity (as defined in section 4965(c)) which is a party to such transaction that such transaction is such a prohibited tax shelter transaction.
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(2) Every tax-exempt entity described in section 4965(c) shall file (in such form and manner and at such time as determined by the Secretary) a disclosure of—(A) such entity’s being a party to any prohibited tax shelter transaction (as defined in section 4965(e)), and(B) the identity of any other party to such transaction which is known by such tax-exempt entity.
Citations to §4965(c)(4)
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(A) In the case of a failure to file a disclosure required under section 6033(a)(2), there shall be paid by the tax-exempt entity (the entity manager in the case of a tax-exempt entity described in paragraph (4), (5), (6), or (7) of section 4965(c)) $100 for each day during which such failure continues. The maximum penalty under this subparagraph on failures with respect to any 1 disclosure shall not exceed $50,000.
Citations to §4965(c)(5)
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(A) In the case of a failure to file a disclosure required under section 6033(a)(2), there shall be paid by the tax-exempt entity (the entity manager in the case of a tax-exempt entity described in paragraph (4), (5), (6), or (7) of section 4965(c)) $100 for each day during which such failure continues. The maximum penalty under this subparagraph on failures with respect to any 1 disclosure shall not exceed $50,000.
Citations to §4965(c)(6)
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(A) In the case of a failure to file a disclosure required under section 6033(a)(2), there shall be paid by the tax-exempt entity (the entity manager in the case of a tax-exempt entity described in paragraph (4), (5), (6), or (7) of section 4965(c)) $100 for each day during which such failure continues. The maximum penalty under this subparagraph on failures with respect to any 1 disclosure shall not exceed $50,000.
Citations to §4965(c)(7)
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(A) In the case of a failure to file a disclosure required under section 6033(a)(2), there shall be paid by the tax-exempt entity (the entity manager in the case of a tax-exempt entity described in paragraph (4), (5), (6), or (7) of section 4965(c)) $100 for each day during which such failure continues. The maximum penalty under this subparagraph on failures with respect to any 1 disclosure shall not exceed $50,000.
Citations to §4965(e)
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(A) such entity’s being a party to any prohibited tax shelter transaction (as defined in section 4965(e)), and
Citations to §4965(e)(1)
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(g) Any taxable party to a prohibited tax shelter transaction (as defined in section 4965(e)(1)) shall by statement disclose to any tax-exempt entity (as defined in section 4965(c)) which is a party to such transaction that such transaction is such a prohibited tax shelter transaction.