Material Advisor

Any person who:

• Provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and
• Directly or indirectly derives gross income in excess of the threshold amount for such aid, assistance, or advice.

The threshold amount is $50,000 if an individual derives substantially all of the tax benefits. For all other cases, the threshold amount is $250,000.