IRS Mulls ‘Unwind’ Rule for Some Gap Period Transactions (1)

The IRS is considering writing a “revision provision” that could partially or fully undo transactions that took place during a gap period between effective dates of two international tax rules.

“There is the possibility of some kind of unwind. We have heard from a number of practitioners that may have some or many clients who would be interested in some unwind of these transactions, so that is another area we’re considering,” said Daniel McCall, deputy associate chief counsel (International-Technical) at the Internal Revenue Service. He spoke Oct. 4 at the American Bar Association tax section meeting in San Francisco.

U.S. ...