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The Centralized Acquirement Service (IRS) has issued PMTA 2018-016, reaffirming its position that for taxpayers authoritative an acclamation beneath Centralized Acquirement Code (Code) Area 965(h) to pay the alteration tax over eight years through chapter payments, any overpayments of 2017 tax liabilities cannot be acclimated as credits for 2018 estimated tax payments or refunded, unless and until the overpayment bulk exceeds the aing eight years of chapter payments.

The IRS’s position has afflicted aing taxpayers, and practitioners bidding their apropos to the IRS to no account — we appraise this hasty development in greater detail below.

On August 8, 2018, the Centralized Acquirement Service (IRS) issued PMTA 2018-016 reaffirming its position that for taxpayers authoritative an acclamation beneath Centralized Acquirement Code (Code) Area 965(h) to pay the alteration tax over eight years through chapter payments, any overpayments of 2017 tax liabilities cannot be acclimated as credits for 2018 estimated tax payments or refunded, unless and until the overpayment bulk exceeds the aing eight years of chapter payments. PMTA 2018-016 relies on Code sections 6402 and 6403, and case law, for its position. This nonbinding acknowledged admonition from IRS Chief Counsel attorneys to IRS cadre marks the aboriginal time the IRS has provided to the accessible its acumen on this subject. We accept ahead discussed this affair actuality

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