The Internal Revenue Service (the "IRS") and the Treasury Department have issued revised tax shelter regulations (the "New Regulations") that are generally effective January 1, 2003. The New Regulations significantly modify and expand the definition of transactions subject to the disclosure rules ("Reportable Transactions") in ways that, unless limited by the IRS, could reach many customary transactions, such as sale-leasebacks, and even non-tax-motivated investments, such as hedge funds. In addition, the New Regulations require certain persons to maintain lists (for IRS inspection) relating to investors in Reportable Transactions. The New Regulations have already elicited numerous comments from tax practitioners and investment bankers, and it is widely expected that the final form of the New Regulations or other IRS pronouncements will provide some clarification regarding the scope of the transactions intended to be covered.