Global Netting: Potential Opportunities for Corporate Taxpayers

WTE Practical International Tax Strategies, Volume 17, Number 8

Global Netting: Potential Opportunities for Corporate Taxpayers

This article was featured in Practical International Tax Strategies and written by James E. Salles, Charles M. Ruchelman and Michael Lloyd of Caplin & Drysdale, Chartered.

Excerpt taken from the article.

Two recent judicial decisions addressing the so-called "global netting" of interest in tax cases potentially offer corporate taxpayers new opportunities. Taxpayers may be able to obtain at least partial netting relief on underpayments and overpayments of federal tax in some circumstances where it had been commonly assumed to be unavailable, and are well-advised to take a second look at their IRS account transcripts in search of previously overlooked claims that may be filed before the statute of limitations expire.

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