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https://www.irs.gov/publications/p225
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https://www.irs.gov/retirement-plans/employee-plans-abusive-tax-transactions
The parties who participate in listed transactions may be required to disclose the transaction as required by the regulations, register the transaction with the IRS, or maintain lists of investors in the transactions and provide the list to the IRS on request

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https://www.irs.gov/individuals/international-taxpayers/fixed-determinable-annual-or-periodical-fdap-income
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https://www.irs.gov/publications/p334
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https://www.irs.gov/publications/p463
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https://www.irs.gov/publications/p17
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https://www.irs.gov/irb/2025-01_IRB
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https://www.irs.gov/publications/p587
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https://www.irs.gov/publications/p541
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https://www.irs.gov/instructions/i1120f
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