98 STAT. 678 26 USC 6111.
PUBLIC LAW 98-369—JULY 18, 1984 "SEC. 6111. REGISTRATION OF TAX SHELTERS. "(a) REGISTRATION.—
"(1) IN GENERAL.—Any tax shelter organizer shall register the tax shelter with the Secretary (in such form and in such manner as the Secretary may prescribe) not later than the day on which the first offering for sale of interests in such tax shelter occurs. "(2) INFORMATION INCLUDED IN REGISTRATION.—Any registra-
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tion under paragraph (1) shall include— "(A) information identifying and describing the tax shelter, "(B) information describing the tax benefits of the tax
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shelter represented (or to be represented) to investors, and "(C) such other information as the Secretary may prescribe. "(b) FURNISHING OF TAX SHELTER IDENTIFICATION NUMBER; INCLUSION ON RETURN.— "(1) SELLERS, ETC.—Any person who sells (or otherwise trans-
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fers) an interest in a tax shelter shall (at such times and in such manner as the Secretary shall prescribe) furnish to each investor who purchases (or otherwise acquires) an interest in such tax shelter from such person the identification number assigned by the Secretary to such tax shelter. "(2) INCLUSION OF NUMBER ON RETURN.—Any person claiming any deduction, credit, or other tax benefit by reason of a tax shelter shall include (in such manner as the Secretary may prescribe) on the return of tax on which such deduction, credit, or other benefit is claimed the identification number assigned by the Secretary to such tax shelter. "(c) TAX SHELTER.—For purposes of this section— "(1) IN GENERAL.—The term 'tax shelter' means any investment— "(A) with respect to which any person could reasonably •"' infer from the representations made, or to be made, in connection with the offering for sale of interests in the investment that the tax shelter ratio for any investor as of oj the close of any of the first 5 years ending after the date on which such investment is offered for sale may be greater than 2 to 1, and ""'•' "(B) which is— ,., "(i) required to be registered under a Federal or State law regulating securities, "(ii) sold pursuant to an exemption from registration requiring the filing of a notice with a Federal or State 1 agency regulating the offering or sale of securities, or "(iii) a substantial investment. "(2) TAX SHELTER RATIO DEFINED.—For purposes of this subsection, the term 'tax shelter ratio' means, with respect to any year, the ratio which— "(A) the aggregate amount of the deductions and 200 percent of the credits which are represented to be potentially allowable to any investor under subtitle A for all periods up to (and including) the close of such year, bears to 105 "(B) the investment base as of the close of such year. "(3) INVESTMENT BASE.—
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