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Is defined as:
- Tax shelter as defined under Internal Revenue Code (IRC) Section 6662(d)(2)(C),
- Reportable transaction as defined under IRC Section 6707A(c)(1) that is not adequately disclosed in accordance with IRC Section 6664(d)(2)(A),
- Listed transaction as defined under IRC Section 6707A(c)(2),
- Gross misstatement within the meaning of IRC Section 6404(g)(2)(D), or
- Transaction to which the noneconomic substance transaction (NEST) penalty applies under Revenue and Taxation Code (RTC) section 19774.
- Browse Related Terms: Abusive tax avoidance transaction (ATAT), Material Advisor, Organizer, Potentially abusive tax shelter, promoter, Red Cross Scheme, Seller, transaction