n-00-15.pdf

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# Part III - Administrative, Procedural, and Miscellaneous

## Listed Transactions

### Notice 2000-15

Transactions that are the same as or substantially similar to transactions described in the
list below have been determined by the Internal Revenue Service to be tax avoidance transactions
and are identified as "listed transactions" for purposes of § 1.6011-4T(b)(2) of the Temporary
Income Tax Regulations and § 301.6111-2T(b)(2) of the Temporary Procedure and
Administration Regulations. As a result, corporate taxpayers may need to disclose their
participation in these listed transactions as prescribed in § 1.6011-4T, and promoters (or other
persons responsible for registering tax shelter transactions) may need to register such transactions
under § 301.6111-2T. In addition, promoters must maintain lists of investors with respect to
these listed transactions pursuant to § 301.6112-1T.

(1) Rev. Rul. 90-105, 1990-2 C.B. 69 (transactions in which taxpayers claim deductions
for contributions to a qualified cash or deferred arrangement or matching contributions to a
defined contribution plan where the contributions are attributable to compensation earned by plan
participants after the end of the taxable year);

(2) Notice 95-34, 1995-1 C.B. 309 (certain trust arrangements purported to qualify as
multiple employer welfare benefit funds exempt from the limits of §§ 419 and 419A of the Internal
Revenue Code);

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(3) Notice 95-53, 1995-2 C.B 334 (certain multiple-party transactions intended to allow
one party to realize rental or other income from property or service contracts and to allow
another party to report deductions related to that income (often referred to as "lease strips"));

(4) Transactions described in Part II of Notice 98-5, 1998-1 C.B. 334 (transactions in
which the reasonably expected economic profit is insubstantial in comparison to the value of the
expected foreign tax credits);

(5) Transactions substantially similar to those at issue in ASA Investerings Partnership v.
Commissioner, No. 98-1583 (D.C. Cir. Feb. 1, 2000) and ACM Partnership v. Commissioner,
157 F.3d 231 (3d Cir. 1998) (transactions involving contingent installment sales of securities by
partnerships in order to accelerate and allocate income to a tax-indifferent partner, such as a tax-
exempt entity or foreign person, and to allocate later losses to another partner);

(6) Prop. Treas. Reg. § 1.643(a)-8 (transactions involving distributions described in
§ 1.643(a)-8 from charitable remainder trusts);

(7) Rev. Rul. 99-14, 1999-13 I.R.B. 3 (transactions in which a taxpayer purports to lease
property and then purports to immediately sublease it back to the lessor (that is, lease-in/lease out
or LILO transactions));

(8) Notice 99-59, 1999-52 I.R.B. 761 (transactions involving the distribution of
encumbered property in which taxpayers claim tax losses for capital outlays that they have in fact
recovered);

(9) Treas. Reg. § 1.7701(l)-3 (transactions involving fast-pay arrangements as defined in §
1.7701(l)-3(b)); and

(10) Rev. Rul. 2000-12, 2000-11 I.R.B. _ , dated March 13, 2000 (certain transactions

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involving the acquisition of two debt instruments the values of which are expected to change
significantly at about the same time in opposite directions).

The principal author of this notice is Richard Castanon of the Office of Assistant Chief
Counsel (Passthroughs and Special Industries). For further information regarding this notice
contact Richard Castanon on (202) 622-3080 (not a toll-free call).