Layla 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.