IRS Releases Chief Counsel Memorandum on Extended Statute of Limitations for Omitted Subpart F Income
The U.S. IRS released a Chief Counsel memorandum on 22 October 2021 concerning whether the extended statute of limitation for omitted subpart F income extends the statute for all items in a tax return. The main points of the memorandum are summarized as follows:
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Statute of Limitations on Assessment under Section 6501(e) and Claims for Credit or Refund under Section 6511
This Chief Coun…
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