USA Client Under IRS examinaion

[Tax88]

Hi - I have a client that is a holding company that is under examination. The service is asking for the corporate minutes, which is a common request. The holding company (which is the only company under audit) does not have any corporate minutes. But, the parent or sub may have corporate minutes. I know that we do not want to provide the corporate minutes for an entity that is not under examination. But, if we say that there are no corporate minutes for the holding company, do we risk having the service disregard the corporate structure?

I think that it is somewhat common not to have minutes for the holding company. How have you guys handled this? Any thoughts or comments would be appreciated.

 

[kirby]

It is commonly understood that all corps need minutes. Many many times the corporate staff does not get around to issuing the minutes of board meetings that were held until somebody needs them.

 

[Tax88]

It is commonly understood that all corps need minutes. Many many times the corporate staff does not get around to issuing the minutes of board meetings that were held until somebody needs them.

I REALLY appreciate the response. But, what if there were no meetings at the holding company level? I have asked several times and they have informed me that they do not have any minutes for the holding company.

 

[kirby]

You have done all you can do. The failure to do something extremely simple is theirs. At this point, it is what it is. Leave it be.

 

[Tax88]

You have done all you can do. The failure to do something extremely simple is theirs. At this point, it is what it is. Leave it be.

Thank you - much appreciated.