These regulations identify certain monetized installment sale transactions and substantially similar transactions as listed transactions, a type of reportable transaction. A listed transaction is defined under section 6707A(c) as a reportable transaction that is the same as, or substantially similar to, a transaction specifically identified by the Secretary as a tax avoidance transaction for purposes of section 6011. Material advisors and certain participants in these listed transactions are required to file disclosures with the IRS and are subject to penalties for failure to disclose. The regulations affect participants in those transactions as well as material advisors. 

The IRS and Treasury solicited and received public comments on the proposed rule and are reviewing and considering those comments, to include those submitted after the comment period closed.