Tax Law Updates | New Statutes, Regulations, and Rulings
February 26, 2010
IRS Issues Emailed Advice on Section 1446 Withholding Liability Issues
Emailed Advice on Section 1446 Withholding Liability Issues
CCA_2009123008484954, 2/5/2010
Through emailed advice, the Internal Revenue Service (“IRS,” or “Service”) has issued guidance relating to resolving section 1446 ( of the Tax Code) withholding liability issues through section 6229(f) settlement agreements.
In its email, the IRS wrote that it can resolve the section 1446 withholding liability by entering into a settlement agreement with the partnership entity (signed by any person with authority under State law to bind the partnership entity). The IRS explained that it may collect and process that case for closure. If there are no other partnership items to be resolved with the partnership entity, then the agreement with…
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