New Federal Reportable Transaction Regulations

Why your tax strategies may expose you to broader IRS scrutiny

Recording of a 100-minute CPE webinar with Q&A

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Conducted on Wednesday, January 10, 2007

Course Materials


The IRS’ oversight of aggressive federal corporate income tax positions just keeps getting tougher. In-house corporate tax professionals and tax counsel need to know about the latest proposal for their company’ sake.

Regulations the IRS proposed in early November would create an entirely new category of tax-saving transactions that would require corporate taxpayers to report “transactions of interest” – those with the potential to get on the government’s bad side.

Clearly, the IRS wants to study evolving, aggressive tax strategies. However, exactly what a “transaction of interest” means is difficult to pin down: Being “substantially similar” to an already listed or reportable transaction leaves much to be interpreted.

Does the government have in mind a tax strategy that your company is already using? If so, what are the implications for your company?

Listen as our panel of savvy tax advisors explains the IRS’ proposed new reportable transaction regulations. You’ll leave the teleconference well-briefed on the meaningful provisions of the regulations, and more importantly better-positioned to analyze the possible impact on your company.



Among the key topics they’ll focus on are:

  • What types of tax positions does the IRS really have in mind when it says “transactions of interest”.
  • How to evaluate whether your company should report its current tax strategies.
  • What is the IRS likely to do with the new intelligence it gathers.
  • Whether your company might have to report “transactions of interest” from prior-year returns.
  • Other relevant changes in the proposed regulations, including new returns and reports required from outside tax advisors and disclosure of patented tax strategies.


Julian Kim
Julian Kim
Latham & Watkins

He specializes in complex federal and state tax controversies involving corporations. As a former acting deputy tax...  |  Read More

Ellis Reemer
Ellis Reemer
DLA Piper

He represents clients in complex federal, state and local tax controversies and litigation. He is a former IRS senior...  |  Read More