Caroline D. Ciraolo was quoted in a recent Tax Notes article entitled “Streamlined Filing May Require Longer Transition Tax Lookback,” published on August 31, 2021. The article addresses the IRS recent modification of the Streamlined Filing Compliance Procedures to expand the lookback period for required amended or delinquent income tax returns to include 2017 where the taxpayer is subject to transition tax under section 965 of the Internal Revenue Code.
The article notes:
Caroline Ciraolo of Kostelanetz & Fink LLP said the announcement of the lookback period expansion was not unexpected given the large amount of tax owed under section 965.
“The expansion is better than the alternative of simply canceling the streamlined filing procedures in advance of 2017 dropping off under the three-year lookback period,” Ciraolo said. “This serves as an important reminder that the streamlined procedures are subject to revision by the Service at any time.”
According to Ciraolo, the announcement does not provide answers for some taxpayers who may have recently made a streamlined submission. She wondered what would happen to taxpayers with a transition tax inclusion who submitted a streamlined filing after May 17 but before the announcement and whether they would be subject to audit and assessment for 2017.
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