Yesterday the IRS published a new practice unit titled “Allowance of Deductions and Credits on 1120-F Delinquent Returns.”
Under Code §882(c)(2), an untimely foreign corporation filer is not entitled to deductions and credits. However, Treas. Reg. §1.882-4(a)(3)(ii) permits the filing deadline to be waived. This practice unit explains the deadline waiver process.
This new practice unit has been added to our Practice Units By Topic page.