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.
Jason Schwartz, Gregg Jubin
Joel Mitnick, Monica Martin, Douglas Gansler
Jason Halper, Nathan Bull, Jared Stanisci, Sara Bussiere, Audrey Curtis