Robert M. Russell was quoted in a Tax Notes article entitled “Transition Tax Campaign’s Focus on E&P Concerns Practitioners,” published on December 3, 2020. Russell observes that return preparers were concerned about the starting point of determining E&P, given that taxpayers may not possess the best records for past years.
The article notes:
“The response from the IRS probably is you should have been properly calculating your E&P
pools from the beginning. It was important for distributions, for subpart F, for foreign tax
credits,” Russell said. “Fair enough. But never before did it all come up at once.”
One issue that especially worried Russell was taxpayers substantially adjusting their cumulative
year-end E&P amount after conducting an E&P study.
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