US taxpayers breathed a collective sigh of relief in April when the Supreme Court delivered its verdict in Home Concrete which stated that the Internal Revenue Service (IRS) was not permitted to use an extended six-year statute of limitations period to investigate overstatements of basis. But there was a broader issue at stake in the case – the IRS’s ability to issue regulations and apply them retroactively. Joe Dalton explores the wider implications of Home Concrete and why US taxpayers will be hopeful the ruling will diminish the IRS’s arsenal in avoidance cases.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
The OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year