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Withdrawal of Directive LMSB-4-0510-017

November 21, 2014

MEMORANDUM FOR All LARGE BUSINESS AND INTERNATIONAL EMPLOYEES
FROM: Douglas W. O’Donnell
Acting Deputy Commissioner (International), Large Business and International Division
SUBJECT: Withdrawal of Directive LMSB-4-0510-017

I. BACKGROUND

On July 26, 2010, the Deputy Commissioner International (LMSB) issued directive LMSB‑4‑0510-017.  This Directive permitted taxpayers to remedy, without having to demonstrate reasonable cause, certain unfiled or deficient gain recognition agreement (GRA) documents.

II. WITHDRAWAL OF DIRECTIVE

Effective as of November 19, 2014, Directive LMSB‑4-0510-017 is withdrawn.  Accordingly, as of November 19, 2014, all requests to remedy unfiled  or deficient GRA documents must be submitted under the relief provisions of Treas. Reg. §1.367(a)‑8(p).  See T.D. 9704 and its accompanying preamble for further information.

III. COORDINATION

Questions regarding this memorandum should be addressed to International Technical Specialist Dorian McCloskey.