DISCLOSURE OF REPORTABLE TRANSACTIONS.

SEC. 815. DISCLOSURE OF REPORTABLE TRANSACTIONS.(a) In General.—Section 6111 (relating to registration of tax shelters) is amended to read as follows:“SEC. 6111. DISCLOSURE OF REPORTABLE TRANSACTIONS.“(a) In General.—Each material advisor with respect to any reportable transaction shall make a return (in such form as the Secretary may prescribe) setting forth—“(1) information identifying and describing the transaction,“(2) information describing any potential tax benefits expected to result from the transaction, and“(3) such other information as the Secretary may prescribe. Such return shall be filed not later than the date specified by the Secretary.118 STAT. 1582“(b) Definitions.—For purposes of this section:“(1) Material advisor.—“(A) In general.—The term ‘material advisor’ means any person—“(i) who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and“(ii) who directly or indirectly derives gross income in excess of the threshold amount (or such other amount as may be prescribed by the Secretary) for such advice or assistance.“(B) Threshold amount.—For purposes of subparagraph (A), the threshold amount is—“(i) $50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and“(ii) $250,000 in any other case.“(2) Reportable transaction.—The term ‘reportable transaction’ has the meaning given to such term by section 6707A(c).“(c) Regulations.—The Secretary may prescribe regulations which provide—“(1) that only 1 person shall be required to meet the requirements of subsection (a) in cases in which 2 or more persons would otherwise be required to meet such requirements,“(2) exemptions from the requirements of this section, and“(3) such rules as may be necessary or appropriate to carry out the purposes of this section.”.(b) Conforming Amendments.—(1) The item relating to section 6111 in the table of sections for subchapter B of chapter 61 is amended to read as follows: “Sec. 6111. Disclosure of reportable transactions.”. (2) So much of section 6112 as precedes subsection (c) thereof is amended to read as follows:“SEC. 6112. MATERIAL ADVISORS OF REPORTABLE TRANSACTIONS MUST KEEP LISTS OF ADVISEES, ETC.“(a) In General.—Each material advisor (as defined in section 6111) with respect to any reportable transaction (as defined in section 6707A(c)) shall (whether or not required to file a return under section 6111 with respect to such transaction) maintain (in such manner as the Secretary may by regulations prescribe) a list—“(1) identifying each person with respect to whom such advisor acted as a material advisor with respect to such transaction, and“(2) containing such other information as the Secretary may by regulations require.” .(3) Section 6112 is amended—(A) by redesignating subsection (c) as subsection (b), (B) by inserting “written” before “request” in subsection (b)(1) (as so redesignated), and(C) by striking “shall prescribe” in subsection (b)(2) (as so redesignated) and inserting “may prescribe”.118 STAT. 1583(4) The item relating to section 6112 in the table of sections for subchapter B of chapter 61 is amended to read as follows: “Sec. 6112. Material advisors of reportable transactions must keep lists of advisees, etc.”. (5)(A) The heading for section 6708 is amended to read as follows:“SEC. 6708. FAILURE TO MAINTAIN LISTS OF ADVISEES WITH RESPECT TO REPORTABLE TRANSACTIONS.” (B) The item relating to section 6708 in the table of sections for part I of subchapter B of chapter 68 is amended to read as follows: “Sec. 6708. Failure to maintain lists of advisees with respect to reportable transactions.”. (c) Effective Date.—The amendments made by this section shall apply to transactions with respect to which material aid, assistance, or advice referred to in section 6111(b)(1)(A)(i) of the Internal Revenue Code of 1986 (as added by this section) is provided after the date of the enactment of this Act.