material advisor

(A)The term “material advisor” means any person— (i)who provides any material aid, assistance, or advice with respect to organizing, managing, promoting, selling, implementing, insuring, or carrying out any reportable transaction, and (ii)who directly or indirectly derives gross income in excess of the threshold amount (or such other amount as may be prescribed by the Secretary) for such aid, assistance, or advice. (B)For purposes of subparagraph (A), the threshold amount is— (i)$50,000 in the case of a reportable transaction substantially all of the tax benefits from which are provided to natural persons, and (ii)$250,000 in any other case.

Source

26 USC § 6111(b)(1)(A)


Scoping language

For purposes of this section
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