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Corporate Tax

03 July 2020
Andrew Roberson Section 965 statutes of limitations for partnerships

USA - McDermott Will & Emery

The Internal Revenue Service (IRS) recently issued guidance on the period of limitations for Section 965 of the Internal Revenue Code transition tax-related adjustments of partnerships. Typically, pursuant to Section 6501, the IRS has three years to assess a tax liability for a tax year. However, Section 6501(e)(1)(C) states that if the taxpayer omits from gross income an amount properly includible in income under Section 951(a), the tax may be assessed at any time within six years after the return was filed.

Authors: Andrew Roberson, Kevin Spencer
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