Apr 01, 2015
“It was in an example, but it wasn't crystal clear. If the IRS doesn't make a request under 6112, the information that’s provided won’t start the one-year statute running."
- Linda Z. Swartz, Chair of the Tax group at Cadwalader, commenting in Law360 on the clarification of certain conditions required to initiate the extended one-year assessment period for undisclosed listed transactions under Section 6501(c)(10), pursuant to recently released IRS regulations.
Dorothy Auth, Howard Wizenfeld
Joshua Apfelroth, Richard Brand, William Mills, Christopher Porcelli, Victoria Saunders
Jean Bertrand, Mark Howe, Jason Schwartz, Gary Silverstein, Linda Swartz, David Teigman, Edward Wei
Jodi Avergun is speaking at this ACI event on January 30 in Washington, DC.