Proceeds (i)Tax-exempt entities that facilitate the transaction by reason of their tax-exempt, tax indifferent or tax-favored status.Solely for purposes of section 4965, in the case of a tax-exempt entity that is a party to the transaction by reason of 53.49654(a)(1) of this chapter, the termproceedsmeans the gross amount of the tax-exempt entity's consideration for facilitating the transaction, not reduced for any costs or expenses attributable to the transaction. Published guidance with respect to a particular prohibited tax shelter transaction may designate additional amounts as proceeds from the transaction for section 4965 purposes.


26 CFR § 53.4965-8

Scoping language

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