The principle of positive silence is removed as a general rule. Therefore, requests made by taxpayers will be deemed rejected if they are not resolved within the legal term by the IRS.
The IRS is not authorized to re-audit or review unless certain specific post-audit event occurs and requirements are met.
Statute of limitations
The IRS is authorized to request documents beyond the statute of limitation period limited to specific cases (i.e., carried-forward losses, VAT credits and tax costs determinations).
Catalog of rights
Certain taxpayers’ rights introduced by the tax reform project are specified and delimited. The special administrative complaint is replaced by a new safeguard claim.