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 Counsel Advice responds to your request for assistance asking whether failure to report subpart F income…