The IRS Large Business & International (LB&I) Division recently announced six new compliance campaigns. LB&I has been steadily adding campaigns, and, to date, LB&I has announced a total of 59 campaigns. LB&I’s goal is to “improve return selection, identify issues representing a risk of non-compliance, and make the greatest use of limited resources.”
The six new campaigns are:
- S corporations built in Gains tax
- Post Offshore Voluntary Disclosure Program (OVDP) compliance
- Expatriation
- High income non-filer
- Erroneous refundable credits in U.S. territories
- Section 457A deferred compensation attributable to services performed before Jan. 1, 2009
Taxpayers should take note because these campaigns are important indicators of where the IRS will spend its audit resources.
Campaign |
Practice area |
Focus |
Treatment stream |
|---|---|---|---|
S corporations built in Gains tax |
Pass through entities |
Increasing awareness of and compliance with payment of built-in Gains tax when C corporations that convert to S corporations have a net unrealized built-in gain and sell assets within five years of conversion |
Issue-based examinations, soft letters and outreach to practitioners |
Post OVDP compliance |
Withholding and international individual compliance |
Addressing tax noncompliance related to former OVDP taxpayers’ who are non-compliant with their foreign income and asset reporting requirements |
Soft letters and examinations |
Expatriation |
Withholding and international individual compliance |
U.S. citizens and long term residents (lawful permanent residents in eight out of the last 15 taxable years) who expatriated on or after June 17, 2008, and may have failed to meet their filing requirements and tax obligations |
Outreach, soft letters and examination |
High income non-filer |
Withholding and international individual compliance |
U.S. citizens and resident aliens who have not filed a tax return, particularly those that did not receive a W-2, Form 1099 or a foreign equivalent of either form |
Examinations |
U.S. territories-erroneous refundable credits |
Withholding and international individual compliance |
Bona fide residents of U.S. territories who erroneously claimed refundable credits on Form 1040 |
Outreach and examinations |
Section 457A deferred compensation attributable to services performed before Jan. 1, 2009 |
Northeastern compliance practice area |
Compensation attributable to services performed before Jan. 1, 2009 that was deferred under a nonqualified deferred compensation plan and was not included in gross income |
Issue-based examinations |
