Succession planning is a critical aspect of managing small, closely held businesses, as the unexpected departure of a key leader can significantly disrupt operations and challenge the business's legal...
Entering into a letter of intent for an office lease agreement? Consult our playbook for valuable key provisions, alternative language provisions, and guidance for both landlords and tenants. Download...
In the complex world of M&A transactions, transition services agreements (TSAs) serve as critical bridges between deal closing and operational independence thus creating stability during organizational...
This practice note covers key legal and regulatory issues to evaluate, questions to ask, and documents to review in medical device or diagnostic technology deals, including M&A, investments, financings...
Statutes of limitation provide the IRS time to review and seek redress for errors in tax returns, whether intentional or not. Under the general rule, the IRS must assess income taxes, estate taxes, and gift taxes within three years from the later of the date the taxpayer's return is due or the date the taxpayer files the return. I.R.C. § 6501(a). Generally, the IRS does this through bulk processing operations at facilities known as IRS Centers, under its authority to assess the taxes shown on returns. I.R.C. § 6201(a)(1). If the taxpayer files the return on or before its due date, the three-year period begins on the due date. I.R.C. § 6501(b)(1). If the taxpayer files the return after its due date, the three-year period begins on the day after the date the return is filed.
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