2014-01-27
Last Friday the IRS published the following Chief Counsel Advice relating to international taxation.
CCA 201404011 - In the context of an OVDI where a taxpayer has filed an amended return and made an overpayment of tax, the IRS cannot credit the overpaid amount to the penalty balance of another tax year. The filing of an amended return does not revive the period of limitation on assessment or refund.
As described earlier, this post may exclude PLRs dealing with typical international related elections.
There were no international PLRs of note for the 3rd week of 2014.
DISCLAIMER
The posts on this blog have not been verified for accuracy. You should consult an attorney for legal advice regarding your own situation. These posts are not updated for changes in the tax laws. Further, these posts should not be relied upon for any purpose whatsoever.
65 Main Street, Centerbrook, Connecticut, 06409 USA | Ph: (860) 767-4975 | Fax: (860) 756-0954
Copyright © 2004 – 2024, Andrew Mitchel LLC. All rights reserved.