8918 Material Advisor Disclosure Statement

Form

8918

Material Advisor Disclosure Statement

OMB No. 1545-0865

(Rev. November 2021)
Department of the Treasury
Internal Revenue Service

▶ See separate instructions.
Note. The reportable transaction number will be sent to the material advisor’s address below.
Material Advisor’s Name (see instructions)
Individual

FOR IRS USE ONLY
Identifying number

Telephone number

Entity
Number, street, and room or suite no.
State

City or town

A

ZIP code

DRAFT AS OF
November 18, 2021
DO NOT FILE

Contact person name (last name, first name, middle initial)

Title

Telephone number

B
Is this a protective disclosure? (see instructions)
If “Yes,” see line 6a instructions.
Yes
No
C
Is this the original Form 8918 for this reportable transaction?
Yes
No
If “Yes,” go to line 1. If “No,” enter the reportable transaction number previously issued for this reportable transaction or tax shelter.
Reportable Transaction Number ▶
1 Name of reportable transaction (see instructions)
2
a
3
4
5

Identify the type of reportable transaction. Check all the box(es) that apply (see instructions).
Listed
b
Confidential
c
Contractual protection
d
Loss
e
Transaction of interest
If you checked box 2a or 2e, enter the published guidance number for the listed transaction or transaction of interest ▶
Enter the date the Material Advisor became a material advisor with respect to the reportable transaction (see instructions) ▶
If you are a party to a designation agreement, identify the other parties (see instructions).
Name
Identifying number (if known)
Individual
Entity

Address (Number, street, and room or suite no.)
City or town

State

ZIP code

Contact name

Telephone number

6a Provide a brief description of the type of material aid, assistance, or advice you provided (see instructions).

b Describe the role of any other entity(ies) or individual(s) who you know or have reason to know provided material aid, assistance, or advice to
this transaction and include each entity’s and individual’s complete name, identifying number (if known), and address.

For Privacy Act and Paperwork Reduction Act Notice, see separate instructions.

Catalog Number 39533A

Form 8918 (Rev. 11-2021)

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Form 8918 (Rev. 11-2021)

7a To obtain the intended tax benefits generated by the transaction:
Yes
Is a related entity(ies) or individual(s) needed?
Is a foreign entity(ies) or individual(s) needed?
Yes
Is a tax-exempt entity(ies) needed?
Yes

No
No
No

b If you answered “Yes” to any of the above questions, describe the role of each individual or entity. Also identify the individual’s or entity’s country
of existence if a particular country is required to obtain the intended tax benefits.

DRAFT AS OF
November 18, 2021
DO NOT FILE

8a To obtain the intended tax benefits generated by the transaction, is income or gain from the transaction allocated directly or indirectly to an
individual(s) or entity(ies) that has a net operating loss and/or unused loss or credits?
Yes
No
b If “Yes,” describe the role of each individual or entity in the transaction.

9

10

Identify the types of financial instruments used in this transaction (see instructions).

Estimated Tax Benefits—Identify the type of tax benefit generated by the transaction that you expect the taxpayer to claim in each year.
Check all boxes that apply (see instructions).
Deductions
Exclusions from gross income
Tax credits
Other

11

Capital loss
Nonrecognition of gain
Deferral

Ordinary loss
Adjustments to basis
Absence of adjustments to basis

Timing of Tax Benefits—If you checked one or more boxes on line 10, check the applicable box(es) below to identify the period in which such
tax benefits are claimed. Check each box that applies.
Tax benefits generated by the transaction are required to be claimed in the first year of participation by the taxpayer.
Tax benefits may be claimed in another year by the taxpayer.

12

Enter the Internal Revenue Code section(s) used to claim tax benefit(s) generated by the transaction. (Attach additional sheets if necessary.)

Catalog Number 39533A

www.irs.gov

Form 8918 (Rev. 11-2021)

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Form 8918 (Rev. 11-2021)

13

Describe the reportable transaction for which you provided material aid, assistance or advice, including but not limited to the following: the
nature of the expected tax treatment and expected tax benefits generated by the transaction for all affected years, the years the tax benefits
are expected to be claimed, the role of the entities or individuals mentioned in lines 7a or 8a (if any) and the role of the financial instruments
mentioned in line 9 (if any). Explain how the Internal Revenue Code sections listed in line 12 are applied and how they allow the taxpayer to
obtain the desired tax treatment. Also, include a description of any tax result protection with respect to the transaction.

DRAFT AS OF
November 18, 2021
DO NOT FILE

Under penalties of perjury, I declare that I have examined this return, and to the best of my knowledge and belief, it is true, correct, and complete.
▲ ▲

Please
Sign
Here

Signature of Material Advisor

Date

Title

Print name

Catalog Number 39533A

www.irs.gov

Form 8918 (Rev. 11-2021)

Form 8918 (Rev. 11-2021)

DRAFT AS OF November 18, 2021 DO NOT FILE

Page 4

DRAFT AS OF
November 18, 2021
DO NOT FILE

DRAFT AS OF November 18, 2021 DO NOT FILE
Catalog Number 39533A

www.irs.gov

Form 8918 (Rev. 11-2021)