Layla Asali Quoted Regarding IRS's Final GRA Regulations in Tax Notes Today

"IRS Releases Final Regs on Gain Recognition Agreements"
Tax Notes Today
11.19.14Layla Asali was quoted regarding the Internal Revenue Service's (IRS) release of regulations on gain recognition agreements (GRAs). The IRS is continuing to take a "sensible approach," Asali said, adding that she was pleased to see that under the final regulations, failure to file or comply with GRA reporting obligations would not trigger a penalty unless the failure was willful. "Considering that a taxpayer that fails to fulfill reporting obligations without reasonable cause is subject to penalties under section 6038B, it is appropriate and sensible for the government to apply a willfulness standard to the question of gain recognition under section 367(a)," she said.
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