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.
Scott Cammarn, Mark Chorazak, Jonathan Watkins,Chris Gavin, Joseph Beach, Peter Morreale
Richard Brand, Stephen Fraidin, Jonathan Watkins, James Fee
Michele Maman, Thomas Curtin, Anthony De Leo, Donny Ariel
Jeffrey Rotblat will discuss "Accumulation/Aggregation/Alternative Exit Strategies" at this event.