Seeking Closure on Tax Position

Overview


Andrew Roberson and Elizabeth Chao wrote this bylined article on challenges in determining if the Internal Revenue Code statute of limitations has expired for a particular tax year or certain items in that year. This determination “is not always straightforward given the statutory framework and myriad of exceptions to the general limitations period,” the authors wrote, particularly for international tax reporting and the new tax law’s provisions on global intangible low-taxed income (GILTI).