A private letter ruling request is a request to the IRS by a taxpayer (an individual, business, or other entity) requesting the IRS to address, in writing, a specific tax situation that applies to the...
The ever-growing number of environmental laws has significantly affected real estate acquisitions. Nearly every purchase agreement will contain environmental representations and warranties, with the seller...
Environmental, social, and governance (ESG) remains an area of intense focus for private fund sponsors, private fund investors, and government regulators. Despite certain regulatory and political headwinds...
Representations and warranties insurance (also referred to as reps and warranties insurance, RWI, or R&W insurance) is designed specifically to cover losses resulting from unknown breaches for all...
Understand the role of ADR mechanisms in drug, medical device, biologics, and other life sciences agreements. Read now » Related Content Life Sciences Due Diligence Considerations in M&A...
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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