TEI Issues Policy Statement on Statutes of Limitation for State and Local Taxes

On April 26, 2016, TEI issued a policy statement on statutes of limitation for state and local taxes. TEI maintains statutes of limitation for assessments and refund claims should be equal; unilateral administrative actions should only toll statutes of limitation for a reasonable, limited period; and when a federal change reopens a state or local statute of limitation, any resulting assessment should be limited to the impact of the federal change on the taxpayer's tax liability unless the taxpayer has signed an agreement extending/modifying the jurisdiction's statute of limitation.

TEI's policy statements reflect TEI's position on important administrative and procedural issues, and facilitate advocacy by providing formal position papers TEI's members can use when communicating with taxing agencies. Other policy statements generated by the State and Local Tax Committee address: (1) Reporting Federal Income Tax Changes, (2) Audit Procedures, (3) Corporate Tax Return Due Dates, (4) State and Local-Imposed Audit Fees, and (5) Interest Rates.

TEI's Statute of Limitations policy statement was prepared under the aegis of TEI's State and Local Tax Committee, whose chair is Jamie Fenwick. Pilar Mata, TEI Tax Counsel, coordinated the preparation of the policy statement. Download the pdf