prohibited reportable transaction
(1) Prohibited tax shelter transaction (A) In general The term “prohibited tax shelter transaction” means— (i) any listed transaction, and (ii) any prohibited reportable transaction. (B) Listed transaction The term “listed transaction” has the meaning given such term by section 6707A(c)(2). (C) Prohibited reportable transaction The term “prohibited reportable transaction” means any confidential transaction or any transaction with contractual protection (as defined under regulations prescribed by the Secretary) which is a reportable transaction (as defined in section 6707A(c)(1) ).