Ancillary agreements play a crucial role in acquisition transactions, complementing and supporting the primary acquisition agreement. Common ancillary agreements include employment agreements, non-competition...
Countering the financing of terrorism remains a top priority of the U.S. government. Financial institutions are obliged to identify terrorists and terrorist organizations included on sanctions lists and...
Power purchase agreements operate as the main source of guaranteed revenue for both traditional and renewable power generation facilities. Because power generation facilities are often financed with non...
Liquidating distributions are the distributions through which a partnership or limited liability company (LLC) terminates a partner's or a member's interest in the entity. Like current distributions...
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) recently issued a nationwide reporting rule effective December 1, 2025. This new rule mandates certain reporting requirements...
Statutes of limitation provide the IRS time to review and seek redress for errors in tax returns, whether intentional or not. Under the general rule, the IRS must assess income taxes, estate taxes, and gift taxes within three years from the later of the date the taxpayer's return is due or the date the taxpayer files the return. I.R.C. § 6501(a). Generally, the IRS does this through bulk processing operations at facilities known as IRS Centers, under its authority to assess the taxes shown on returns. I.R.C. § 6201(a)(1). If the taxpayer files the return on or before its due date, the three-year period begins on the due date. I.R.C. § 6501(b)(1). If the taxpayer files the return after its due date, the three-year period begins on the day after the date the return is filed.
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