IRS CCA Advises on Foreign Partnership’s Repo Transactions Protected by Trading Safe Harbor

The IRS Chief Counsel’s Office advised on whether the IRS may proceed with issuing a Final Partnership Administrative Adjustment (FPA) when the Notice of Administrative Proceeding (NAP) was not sent to the partnership’s Last Known Address (LKA). The Chief Counsel’s Office recommended proceeding with the FPA, concluding that the Bipartisan Budget Act does not provide statutory remedies for failure to mail the NAP to the LKA and that FPA issuance is not tied to proper NAP issuance under I.R.C. §6231. [CCA 202611009]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.