Department of the Treasury — Internal Revenue Service Form 13976 OMB No. 1545-1686 (April 2008) Itemized Statement Component of Advisee List Section I: Material Advisor Information Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Telephone Number Person to Contact Section II: Reportable Transaction Information Name of Reportable Transaction Type(s) of Reportable Transaction Reportable Transaction # Published Guidance # (TOI or Listed Transactions) Section III: Other Material Advisors to the Reportable Transaction 1) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Signed Designation Agreement: Yes No 2) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Signed Designation Agreement: Yes No 3) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Signed Designation Agreement: Yes No Section IV: Advisee Information and Summary or Schedule of Tax Treatment 1) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) Catalog Number 51488Y www.irs.gov Form 13976 (Rev. 04-2008) |
Page 2 of 6 Section IV: Advisee Information and Summary or Schedule of Tax Treatment (Continued) 2) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) 3) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) 4) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) 5) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) Catalog Number 51488Y www.irs.gov Form 13976 (Rev. 04-2008) |
Page 3 of 6 Section IV: Advisee Information and Summary or Schedule of Tax Treatment (Continued) 6) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) 7) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) 8) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) 9) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) Catalog Number 51488Y www.irs.gov Form 13976 (Rev. 04-2008) |
Page 4 of 6 Section IV: Advisee Information and Summary or Schedule of Tax Treatment (Continued) 10) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) 11) Name (Last/Entity) First Name Taxpayer Identification Number (TIN) Street Address City State Zip Date Entered into Transaction Amount Invested Summary or Schedule of the Tax Treatment that Advisee is Expected or Associated Documents, such as Exhibit Intended to Derive from Participation in Reportable Transaction and/or Bates Numbers (Optional) Privacy Act Notice and Paperwork Reduction Act Notice We ask for the information on this form to carry out the Internal Revenue laws of the United States. We need it to ensure that you are complying with these laws. Our authority to ask for this information is Internal Revenue Code sections 6112 and 6708 and their regulations, which require you to furnish this information to us within 20 business days after we request it from you in writing. Section 6109 requires that you provide your identifying number on what you file; this is so that we can properly process your filed documents. Use of this form is optional, but providing the information requested on this form is mandatory. We may disclose this information to the Department of Justice for civil and criminal litigation, and to other federal agencies as provided by law. We may give it to cities, states, the District of Columbia, and U.S. commonwealths or possessions to carry out their tax laws. We may also disclose this information to other countries under a tax treaty, to federal and state agencies to enforce federal nontax criminal law, or to federal law enforcement and intelligence agencies to combat terrorism. Failure to maintain and furnish this information as required, or providing false or incomplete information, may subject you to penalties. The collection of information referenced in this form have been previously reviewed and approved by the Office of Management and Budget (OMB) as part of the promulgation of § 6112 in accordance with the Paperwork Reduction Act (44 U.S.C. 3507) under control number 1545-1686. Material Advisors are required to maintain this information. If requested, Material Advisors are required to provide this information to the Internal Revenue Service. The revenue procedure merely provides a format for material advisors to use in complying with the requirements of § 6112. This form is not required. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless the collection of information displays a valid OMB control number. Books or records relating to a collection of information must be retained as long as their contents may become material in the administration of any internal revenue law. Generally, tax returns and return information are confidential, as required by § 6103. The estimated annual burden per recordkeeper for this collection of information is 100 hours and the estimated number of recordkeepers is 500. Catalog Number 51488Y www.irs.gov Form 13976 (Rev. 04-2008) |
Page 5 of 6 General Instructions Purpose of the Form Section II - Reportable Transaction Information Note. The use of this Form (or a similar form) is voluntary. Name of Reportable Transaction. Enter the name, if any, by The use of this Form is not required in order to comply with which the transaction is known or commonly referred to by section 6112. either the material advisor or published guidance. If no name exists, leave blank. Do not report more than one type of As per Regulations section 301.6112-1(b)(1) and Rev. reportable transaction on this Form unless the transactions are Proc. 2008-20, this Form provides material advisors a the same or substantially similar. format for preparing and maintaining the itemized statement component of the list with respect to a Type of Reportable Transaction. Enter the type of reportable transaction. This Form contains space for all reportable transaction that is being reported. The types of of the elements required by Regulations section reportable transactions are: listed transactions, confidential 301.6112-1(b)(3)(i), as revised on August 3, 2007. transactions, transactions with contractual protection, loss transactions, and transactions of interest. See Regulations Material advisors may use this Form as a template for sections 1.6011-4(b)(2)-(6) for the descriptions of the creating a similar form, including a spreadsheet, on a reportable transactions. Prior reportable transactions include software program used by the material advisor. transactions with a significant book-tax difference and transactions with a brief asset holding period. If a material advisor is required to maintain a list under a prior version of the regulations, this Form may be Reportable Transaction Number. If you disclosed the modified or a similar form containing all the information transaction as a reportable transaction under section 6111, required under the prior version of the regulations may enter the reportable transaction number issued to you. be created and used. Published Guidance Number. If the transaction is a listed transaction or transaction of interest, enter the notice, revenue Use of the Form ruling, regulation, announcement, or other published guidance Material advisors may use this Form (or a similar form) that identified the transaction as a listed transaction or and provide this Form (or a similar form), along with a transaction of interest (For example, Notice 2003-81, 2003-51 description of the transaction and copies of documents I.R.B. 1 modified and supplemented by Notice 2007-71, required under Regulations section 301.6112-1(b)(3)(ii) 2007-35 I.R.B. 472.). For listed transactions, identify the and (iii), respectively, when timely furnishing the list in guidance as shown in Notice 2004-67, 2004-50 I.R.B. 967 or response to a written request for the list. later IRS guidance. Specific Instructions Section III - Other Material Advisors to the Reportable Transaction How to Complete the Form In order to be considered complete, this Form (or a similar Enter the names of other material advisors to the transaction, if form) must be completed in its entirety. To be considered known. Use more than one page if necessary. complete, the information provided on this Form (or similar form) must include a summary or schedule of the tax treatment Individuals. If any other material advisor is an individual, that the advisee is intended or expected to derive from enter the last name and first name, the complete address, and participation in the reportable transaction. A statement that the social security number (if known) of the material advisor. information will be provided upon request is not considered a Indicate with a "yes" or "no" whether the other material advisor complete Form. If the list is being maintained under a prior is a party to a designation agreement with respect to the version of Regulations section 301.6112-1, the Form must transaction. contain all of the information required under the prior version in order to be complete. Entities. If any other material advisor is an entity, enter the full name of the entity as shown on its income tax return, the If the information required exceeds the space provided, employer identification number (if known), and the complete complete as much information as possible in the available address. Indicate with a "yes" or "no" whether the other space and attach the remaining information on additional material advisor is a party to a designation agreement with sheets. The additional sheets must be in the same order as respect to the transaction. the lines to which they correspond and should be clearly labeled to identify the Section of the Form to which they Caution: The designation of one material advisor to disclose correspond. You must include your name and identifying the transaction does not relieve you from the requirements of number at the top of each additional sheet. Regulations section 301.6112-1 if the IRS is unable to obtain the list from the designated material advisor, the designated Section I - Material Advisor Information material advisor did not maintain a list, or the list maintained by the designated material advisor is incomplete. Individuals. If the material advisor is an individual, enter the last name and first name, the complete address, the phone number, and the social security number of the material advisor. Entities. If the material advisor is an entity, enter the full name of the entity as shown on its income tax return, the complete address, the employer identification number, and the name of a contact person along with a contact telephone number. Catalog Number 51488Y www.irs.gov Form 13976 (Rev. 04-2008) |
Page 6 of 6 Section IV - Advisee Information and Summary or Summary or Schedule of the Tax Treatment that Advisee Schedule of Tax Treatment is Expected or Intended to Derive From Participation in Reportable Transaction. Enter a summary or a schedule of Provide the following information for each person or entity for the tax treatment that each advisee is expected or intended to which you acted in your capacity as a material advisor with derive from participation in each reportable transaction. respect to the reportable transaction described on this Form (or similar form). Use more than one page if necessary. The tax treatment that an advisee is intended to derive is the purported or claimed Federal tax treatment of the transaction. Individuals. If the advisee is an individual, enter the last name and first name, the complete address, the social security If the information required exceeds the space provided, follow number, the date the person entered into the transaction (if the procedures under How to Complete the Form. known), and the amount of money the person invested in the reportable transaction (if known). Associated Documents. This column is optional. If there are any documents or exhibits associated with the advisee for the Entities. If the advisee is an entity, enter the full name of the reportable transaction described on this Form (or similar form) entity as shown on its income tax return, the complete that are labeled, the Bates numbers or other information address, the employer identification number, the date the identifying the associated documents may be entered in this entity entered into the transaction (if known), and the amount column. of money the entity invested in the reportable transaction (if known). Catalog Number 51488Y www.irs.gov Form 13976 (Rev. 04-2008) |