Statute of limitations extension.

Except as provided in par. (b), if a taxpayer fails to provide any information regarding a reportable transaction, other than a listed transaction, under sub. (2), the time for assessing any tax imposed under this chapter with respect to that transaction shall expire no later than the date that is 6 years after the date on which the return for the taxable year in which the reportable transaction occurred was filed. If a taxpayer fails to provide any information regarding a listed transaction, under sub. (2), the time for assessing any tax imposed under this chapter with respect to that transaction shall expire on the latest of the following dates: 1. The date that is 6 years after the date on which the return for the taxable year in which the listed transaction occurred was filed. 2. The date that is 12 months after the date on which the taxpayer provides information regarding the listed transaction under sub. (2). 3. The date that is 12 months after the date on which the taxpayer’s material advisor provides, at the department’s request, the list described in sub. (7) (b). 4. The date that is 4 years after the date on which the department discovers a listed transaction that was a listed transaction on the date the transaction occurred for which the taxpayer did not provide the information described under sub. (2) or for which the taxpayer’s material advisor did not provide the information described under sub. (7) (b).

Any limitation determined under par. (a) may be extended by a written agreement between the taxpayer and the department as provided under s. 71.77 (5).

This subsection applies to any reportable transaction, including a listed transaction entered into on or after January 1, 2001, or entered into prior to January 1, 2001, that reduced the taxpayer’s tax liability for taxable years beginning on or after January 1, 2001.