Statute of Limitations Internal Revenue Service

Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period... more +
Statute of Limitations refers to a statute that sets the time period during which a legal claim can be brought. Most statute of limitations laws require individuals to sue at some point during a set period usually commencing from the date of the wrong or injury or the discovery of the wrong or injury. Except for under a limited set of circumstances, if an individual does not file a suit within the specified time period, the law bars them from ever suing on that claim. less -
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MoFo New York Tax Insights - Volume 5, Issue 11 - November 2014

In This Issue: - Court Orders Department of Finance to Release Corporate Tax Return Records to City Comptroller - ALJ Upholds State Tax Department Policy on Personal Liability of LLC Members for Sales...more

Court Weighs in on Deadline for Filing FTC Refund Claims

On September 19, 2014, the U.S. Court of Federal Claims issued its opinion in Albemarle Corp. v. United States, No. 12-184T, holding that it lacked jurisdiction over the taxpayer’s claim for refunds based on foreign tax...more

M&A statutes of limitations: Delaware moves to vanquish a legal relic

In a world of continuous innovation, it is an understatement that to varying degrees the law lags behind the times. But even measured by the glacial pace of judicial and statutory change, the notion of a corporate “seal” –...more

The ERISA Litigation Newsletter - February 2014

The employee benefits issues to be considered by the U.S. Supreme Court continue to be of great significance to plan sponsors and fiduciaries. This month we review the Court's employee benefit decisions from 2013 and also...more

Employment Tax Refunds Now Available to Same-Sex Married Couples and Employers

In a notice issued this week (Notice 2013-61), the IRS established special procedures for employees with same-sex spouses and their employers to correct overpayments of income and FICA taxes attributable to the employees’...more

IRA Beneficiary Suffers Transferee Estate Tax Liability 12 Years After Form 706 Filed

Notwithstanding failing to assess estate tax against an IRA beneficiary wihin the Code §6901 four year transferee statute of limitations, in U.S. v. Maureen G. Mangiardi et al, the IRS was permitted to collect estate taxes...more

The ERISA Litigation Newsletter - May 2013

This month our articles focus on the availability of damages in complex ERISA class actions and withdrawal liability actions. Jackie Len first provides Proskauer's perspective on the implications for ERISA litigation arising...more

Sixth Circuit Denies Government Motion for Rehearing in Quality Stores Employment Tax Challenge

The Sixth Circuit has unanimously and summarily denied a Government request for en banc rehearing of a taxpayer-favorable ruling in United States v. Quality Stores, Inc., 693 F.3d 605 (6th Cir. Sept. 7, 2012)....more

Death and Taxes? Recent Supreme Court Arguments in Gabelli v. SEC Concerning a General Statute of Limitations for Civil Fines May...

On January 8, the Supreme Court of the United States heard oral arguments in Gabelli v. S.E.C., 133 S. Ct. 97 (2012) on the question: By when must the government initiate an action to enforce a civil fine, penalty, or...more

White Collar Watch - January 2013

In This Issue: - Death and Taxes? Recent Supreme Court Arguments in Gabelli v. SEC Concerning a General Statute of Limitations for Civil Fines May Also Affect How Long the IRS Has to Assess Penalties - Avoiding...more

Sooner Rather Than Later For Gift Tax Returns

Late 2012 saw an unprecedented amount of gifting, as taxpayers sought to use up their unified credit before it was slated to shrink up in 2013. As a result, the IRS should be swamped with gift tax returns for 2012. Taxpayers...more

Employers May Be Entitled to FICA Tax Refund On Severance Payments

If the recent decision of the Sixth Circuit Court of Appeals in United States v. Quality Stores survives appeal by the IRS, employers could be entitled to a refund of FICA taxes paid by them after 2008 on severance payments...more

Government Challenges Sixth Circuit Decision in Quality Stores, Inc.

On October 18, 2012, the U.S. Department of Justice filed a petition for rehearing en banc in the Sixth Circuit Court of Appeals in United States v. Quality Stores, Inc., No. 10-1563 (September 7, 2012), asking the full court...more

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