For purposes of this subpart 2, unless the context otherwise requires: (1) "Colorado combined group" means a group of affiliated C corporations required or allowed to file a combined report pursuant to section 39-22-303. (2) "Department" means the department of revenue. (3) "Income tax" means a tax imposed under this article. (4) "Income tax return" means a return filed under section 39-22-601. (5) "Listed transaction" means a transaction that is: (a) The same as, or substantially similar to, a transaction or arrangement specifically identified as a listed transaction by the United States secretary of the treasury in written materials interpreting the requirements of section 6011 of the internal revenue code; (b) A transaction between a captive real estate investment trust as defined in section 39- 22-503 (2) and its more than fifty percent beneficial owner as described in section 39-22-503 (2)(a); or (c) A transaction between a captive regulated investment company as defined in section 39-22-501 (2) and its more than fifty percent beneficial owner as described in section 39-22-501 (2)(a). (6) "Material advisor" shall have the same meaning as set forth in section 6111 of the internal revenue code. (7) "Reportable transaction" means any transaction or arrangement that is the same as any transaction or arrangement described in 26 CFR 1.6011-4 (b)(2) to (b)(6) but shall not include any transactions specifically excluded by the internal revenue service.
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