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Friday, February 24, 2012

Congress Repeals All Special Estimated Payment Rules for Corporations with $1 Billion in Assets

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 Congress has periodically altered the amount of certain required estimated tax payment installments for corporations with assets of at least $1 billion (determined as of the end of the preceding tax year). These altered installment payments were due in July, August or September of the corporation's tax year (with a corresponding reduction in the next required installment). After a series of non-Code legislative changes implementing these alterations for 2012, 2014, 2015, 2016 and 2019, Congress repealed all prior legislative changes as part of the Middle Class Tax Relief and Job Creation Act of 2012 (P.L. 112-96, §7001) signed by President Obama on February 22, 2012. The repeal thus restores the §6655 payment regime as if all prior acceleration provisions never were enacted.

Kenneth S. Savell, J.D., LL.M.
IRS Practice and Procedure Group
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