IRS Mulls Proposals to Classify More Transactions as ‘Listed’

The IRS may propose requiring disclosure of more international transactions, similar to its recent proposal to disclose transactions in Maltese retirement plans, an IRS official said Tuesday.

The agency is “actively considering” proposals that would classify other transactions as “listed transactions,” said James Kelly, deputy associate chief counsel for controversy and litigation in the IRS Office of Associate Chief Counsel (International). That would require material advisers and participants in the transactions to report them to the IRS and would subject them to penalties if they didn’t.

Kelly, who spoke at a virtual conference of the US branch of ...