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Proposed Regulations Provide 120-Day Period for Taxpayer Authorizations for Release of Returns and Return Information to Third Party

March 17, 2011 | No. 2011-129


The Treasury Department and IRS today released for publication in the Federal Register proposed regulations (REG-153338-09) that would extend to 120 days (from 60 days) the period for submitting taxpayer authorizations permitting IRS disclosure of returns and return information to a taxpayer’s designee(s).

For an electronic version of today’s proposed regulations (10 pages): REG-153338-09

Overview

The preamble to today’s proposed regulations explains that certain institutions that are assisting taxpayers in their financial dealings and that may need disclosure of returns or return information have encountered difficulty in obtaining written authorizations and submitting these authorizations to the IRS in a timely manner. Under existing regulations, a written authorization must be received by the IRS within 60 days of when it was signed and dated by the taxpayer.

Today’s proposed regulations would extend to 120 days, the period within which taxpayer-provided authorizations must be received by the IRS (or an agent or contractor of the IRS) in order to be effective.

This change is proposed to be effective with the publication in the Federal Register of final regulations. The regulation, once effective, will apply to section 6103(c) authorizations signed on or after October 19, 2009.

 

REG-153338-09 will appear in the Federal Register on Friday, March 18, 2011.

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ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY KPMG TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.

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