Complying with the reportable transaction disclosure rules has become more complex, and noncompliance can create significant risk, including federal penalties of up to $200,000 per transaction.

In addition to "failure to disclose" penalties, companies also must consider accuracy-related penalties for understatements of tax attributable to certain reportable transactions. Such penalties can reach 30 percent of the applicable understatement. In certain cases, these penalties also may have to be disclosed to the Securities and Exchange Commission.

Our Tax Controversy Services group can help your company keep pace with the requirements for reportable transactions and address exposure to the new penalties. This group includes specialists who spend significant time on the reportable transaction disclosure rules and have significant knowledge from having consulted on, advised about and discussed reportable transaction issues with hundreds of companies in diverse industries.

We can assist with:

• Training
• Risk assessment
• Communication planning
• Implementation plan development
• Data collection
• Transaction analysis 
• Disclosure preparation
• Documentation and record retention
• Process improvement
• Internal Revenue Service audit assistance, including responding to the “Super” Information Document Request

For more information, see the PDF attached below.