Identifying Basket Contract Transactions as Listed Transactions

Summary

This practice note discusses proposed regulations issued by the Internal Revenue Service (IRS) and the U.S. Department of the Treasury (Treasury Department) under I.R.C. Section 6011 that would identify, as listed transactions, transactions that are the same as certain basket transactions or substantially similar to certain basket contract transactions. Listed transactions are a type of reportable transaction. The proposed regulations add Proposed Treasury Regulations Section 1.6011-16.