For corporations, however, overpayment interest and underpayment interest accrue at different rates. Currently, the underpayment rate can be as high as 5% (large corporate underpayment rate or “hot interest”), despite the fact that the overpayment interest rate can be as low as 0.5% (GATT* rate).
*The General Agreement on Tariffs and Trade (GATT) legislation established a lower credit interest rate for large corporate overpayments.
However, the “interest rate netting” provisions of the Code allow the underpayment rate to be reduced to match the lower overpayment rate, or the overpayment rate to be increased to match the higher underpayment rate, during overlapping interest periods. Interest rate netting is just one example of taxpayer-favorable interest provisions that the taxpayer must request proactively.
IRS manually computes interest
Even without consideration of such provisions, IRS interest computations are often complex and difficult to decipher because the calculations can span several tax years and address a number of items. The IRS is required to compute interest “manually” when a taxpayer’s fact pattern has been complicated by examination assessments, amended returns, net operating loss carrybacks, or other such factors.
During this manual process, correctly identifying starting and ending dates and suspension periods can be challenging, especially given a more intricate fact pattern. Taxpayers run a risk of “leaving money on the table” by assuming that interest as calculated by the IRS is correct.
Taxpayers who answer yes to some of the following questions may benefit from evaluating whether the related interest was properly determined:
- Is your return currently being examined by the IRS, or has the IRS completed an examination of your return(s) within the past two to three years?
- If exams have been completed, did the IRS make any adjustments (assessments or abatements) for one or more years?
- Have you filed any net operating loss carryback claims within the last two to three years?
- Have you filed any amended returns and paid additional tax and interest?
- Do you normally elect to have overpayments applied to the next tax year instead of having them refunded?
The more questions answered “yes”—the more potential there is for benefit to be found in an account review.
Taxpayers that have been subject to tax assessments or abatements may want to consider certain action steps, including:
- Reviewing their complete IRS account to determine if all interest calculations are correct or whether there are potential errors that could affect overpayment and/or underpayment interest
- Reviewing the rates of interest, interest suspension periods, and the start and end dates of interest computations
- Identifying opportunities to reduce interest by application of offsets, credits, and interest netting
- Preparing claims for refund or abatement of interest
KPMG’s Complex Interest Services Group can review tax account transcripts to identify IRS computation errors or proactively request application of interest rules that are favorable to taxpayers.
For more information, contact a tax professional in KPMG’s Complex Interest Services Group: