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|
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Effective as of November 19, 2014, Directive LMSB‑4-0510-017 is withdrawn.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.
Questions regarding this memorandum should be addressed to International Technical Specialist Dorian McCloskey.