New Wisconsin Disclosure Requirements And Amnesty Program — May 31, 2008 Due Date

Wisconsin requires that taxpayers make certain disclosures of transactions the Internal Revenue Service (IRS) has designated as "reportable transactions" or "listed transactions." These requirements apply retroactively to applicable transactions entered into on or after January 1, 2001, and transactions entered into before January 1, 2001 that reduced the taxpayer's tax liability for taxable years beginning on or after January 1, 2001. See 2007 Wis. Act 20 § 2138 (creating Wis. Stat. § 71.81).

Taxpayers are eligible to receive a waiver of all penalties with respect to "tax avoidance transactions" if the taxpayer files an amended tax return reporting the total Wisconsin net income and tax for the applicable taxable year, computed without regard to any tax avoidance transaction and without regard to any other adjustment that is unrelated to any tax avoidance transaction, and timely pays the resulting