Requirement of statement disclosing participation in certain transactions by taxpayers.

(a) In general. If a transaction is identified as a listed transaction or a transaction of interest as defined in § 1.6011-4 of this chapter by the Commissioner in published guidance, and the listed transaction or transaction of interest involves a tax on generation-skipping transfers under chapter 13 of subtitle B of the Internal Revenue Code, the transaction must be disclosed in the manner stated in such published guidance. (b) Effective/applicability date. This section applies to listed transactions and transactions of interest entered into on or after November 14, 2011. [T.D. 9556, 76 FR 70341, Nov. 14, 2011]