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ARTICLE · 21 APRIL 1999

Retroactive Interest Netting: IRS Guidance in Rev. Proc. 99-191

Sutherland Asbill & Brennan LLP
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United StatesAccounting and Audit
By James V. Heffernan

April 14, 1999

Section 6621(d), as enacted by the Internal Revenue Service Restructuring and Reform Act of 1998, P.L. 105-206, was designed to deal with the inequity of having an interest rate differential (a higher interest rate on underpayments than the interest rate on overpayments) during periods of mutual indebtedness between a taxpayer and the IRS. The effective date of section 6621(d) generally is for interest for periods beginning after July 22, 1998 (the date of enactment of the 1998 legislation). However, a special rule provides that taxpayers can request interest netting for periods beginning before July 22, 1998 (referred to here as "retroactive interest netting"), subject to certain specified conditions.2

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