Global Interest

Interest Netting

Interest Netting May Be Worth More Than You Think

It may be worth your while to reexamine the benefit of IRC Sec. 6621(d)’s interest netting to the amount of interest paid to and received from the IRS. Recent court decisions have expanded the meaning of “same taxpayer” by allowing interest netting between parents and their subsidiaries with different taxpayer identification numbers (TIN).   Ultimately, you […]

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Statute of Limitations

Statute of Limitations for Interest May be Much Longer Than You Think

The statute of limitations (SOL) for an interest claim runs two, three, or six years depending on whether the interest you’re claiming arose out of an underpayment or overpayment. Understanding which limitations period applies is an essential step in protecting your rights to file an interest claim. Congress has clearly distinguished between interest charged on

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