Sec. 2500.5. Form, timing,and content of disclosure of New York reportable transactions

Tax Law, § 25(a)(2), (e)

(a) A taxpayer subjectto disclosure as required by Tax Law, section 25(a)(2) is requiredto report such disclosure on the forms and in the manner prescribedby the commissioner.

(b) If a transactionbecomes a New York listed transaction after the filing of a taxpayer'stax return reflecting either tax consequences or a tax strategy describedin the notice or other form of published guidance listing the transaction(or a tax benefit derived from tax consequences or a tax strategydescribed in the notice or other form of published guidance listingthe transaction) and before the end of the period of the statute oflimitations for the tax return (whether or not already filed) reflectingthe tax consequences, tax strategy, or tax benefit, then a taxpayermust disclose the New York listed transaction on the forms and inthe manner prescribed by the commissioner with the tax return nextfiled after the date the transaction is listed regardless of whetherthe taxpayer participated in the transaction in that tax year.

(c) The disclosure andfiling requirements of this Part are in addition to any other disclosureor filing requirements, general or specific, provided by law.