United States

Large Business and International division releases 13 campaigns

IRS moves toward campaigns to focus compliance efforts

TAX ALERT  | 

On Jan. 31, the IRS Large Business and International (LB&I) division announced that they have identified and selected 13 specific issues to focus their compliance efforts around. In September 2015, LB&I announced a move to issue specific, or ‘campaign,’ examinations that will be effectuated by determining which compliance areas present a risk that requires responses from one or more treatment streams to achieve compliance. Using data analysis and feedback from LB&I examination teams, LB&I has identified its first set of campaign issues with the goal of improving return selection, identifying issues with a risk of non-compliance and maximizing LB&I’s limited resources.

Following are the campaigns, practice areas, treatment stream and lead executive:

Campaign

Practice area

Treatment stream

Lead executive

Section 48C energy credit

Enterprise activities

Soft letters

Issue-focused examinations

Kathy Robbins

OVDP declines-withdrawals

Withholding and international individual compliance

Vary, including examination

Pamela Drenthe

DPAD for multi-channel video program distributors and broadcasters

Enterprise activities

Development of an externally published practice unit

Potential published guidance

Issue-based exams, when warranted

Kathy Robbins

Micro-captive insurance

Enterprise activities

Issue-based examinations

Gloria Sullivan

Related party transactions

Enterprise activities

Issue-based examinations

Peter Puzakulics

Deferred variable annuity reserves and life insurance reserves

Enterprise activities

Develop published guidance for taxpayers

Kathy Robbins

Basket transactions

Enterprise activities

Issue-based examinations

Soft letters to material advisors

Practitioner outreach

Gloria Sullivan

Land developers - completed contract method

Enterprise activities

Develop a practice unit

Soft letters

Issue-based examinations when warranted

Peter Puzakulics

TEFRA linkage plan strategy

Pass-through entities

Develop new procedures and technology to work with TEFRA examining agent

Cliff Scherwinski

S corporation losses claimed in excess of basis

Pass-through entities

Issue-based examinations

Soft letters

Stakeholder outreach

Creation of a new form in computing basis

Holly Paz

Repatriation

Cross border activities

Improve issue selection filter

Identify high-risk issues

John Hinding

Form 1120-F non-filer

Cross border activities

Soft letter outreach

Examination where warranted

John Hinding

Inbound distributor

Treaty and transfer pricing operations

Issue-based examinations

Sharon Porter

LB&I is continuing to identify campaigns that they wish to pursue. Taxpayers who have activities involving any of these campaigns should contact their tax advisors to ensure they are prepared for potential IRS activity.


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