Omission without a saving clause removes the basis for penalties tied to Form 3CEB reporting of specified domestic transactions.
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....Omission of the provision defining related-party purchases as specified domestic transactions, without a saving clause, removed the statutory foundation for penalties for failure to furnish Form 3CEB. Omission is distinguished from repeal: absent a saving provision, it does not preserve a right to initiate or continue proceedings based on the omitted provision. Penalties imposed for the relevant assessment years were therefore unsustainable.....
TaxTMI