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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The Court of Appeals for the Federal Circuit denies refund of additional interest requested by the Ford Motor Company (Nov. 13, 2018)

The Court of Appeals for the Federal Circuit has affirmed a decision by the U.S. Court of Federal Claims (Fed Cl, 2017-1 USTC ¶550,239) which denied the Ford Motor Company’s (Ford) claim that the Parent and its wholly owned Foreign Sales Corporation (FSC) were the “same taxpayer” for purposes of global interest netting.  This decision

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Revenue Procedure 2000-26: The Guidance for Taxpayers and IRC 6621(d)

On May 24, 2000 the IRS issued a procedure providing guidance to taxpayers seeking to obtain the benefits of IRC 6621(d) net rate zero interest rate.  IRC Sec. 6621(d), which was enacted in 1998, is a direct legislative response to the IRS’s sluggishness in remedying the interest rate differential’s inequity. IRC 6621(d) eliminates the interest

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