IRS Mulls Closing Agreements for Repatriation Double Tax Relief

Treasury will likely use closing agreements, rather than private letter rulings, to grant relief to taxpayers with repatriated earnings that are taxed twice under some circumstances, an IRS official said Friday.

“The problem is not of the Treasury or IRS’s making,” Peter H. Blessing, IRS associate chief counsel (international) said. “It’s the way the statute got drafted, so sometimes you need to do it through a closing agreement.”

Blessing was responding to a question at an American Bar Association conference in Boca Raton, Fla.

• The IRS told taxpayers who fit a certain fact pattern to call the ...