(a) Authorization.

Section 25(a)(3) of the Tax Law authorizes thecommissioner to promulgate regulations with regard to New York reportabletransactions.

(b) Brief descriptionof a New York reportable transaction.

A New York reportable transaction is a transaction that has thepotential to be a tax avoidance transaction under article 9, 9-A,22, 32, or 33 of the Tax Law.

(c) Purpose.

Taxpayers who participate in New York reportabletransactions are required to disclose their participation to the department.