United States

IRS LB&I Division announces additional compliance campaigns

The campaigns cover 11 topics spread over six practice areas


On Nov. 3, 2017, the Large Business & International (LB&I) Division of the IRS announced that it was adding 11 new compliance campaigns to the existing 13 campaigns that were announced earlier this year. LB&I originally created the campaigns to ensure taxpayer examinations remain issue-based. The campaigns are intended to focus on compliance issues that present the greatest risk of non-compliance. The original 13 campaigns, as well as the newly announced campaigns, were identified through the suggestions of IRS compliance employees and LB&I data analysis.

Unlike with the original 13 Campaigns, where LB&I planned on addressing the issues through a variety of actions ranging from issue based examinations to publishing clear guidance, LB&I will address each of the new 11 campaigns through examination.

Following are the campaigns, practice areas, focus of the campaign, and lead executive:


Practice Area


Lead Executive

Form 1120-F Chapter 3 and Chapter 4 Withholding

Withholding & International Individual Compliance

Verification of the withholding credits before the claim for refund or credit is allowed

John Cardone

Swiss Bank Program

Withholding & International Individual Compliance

Address noncompliance involving taxpayers who are or may be the beneficial owners of the Swiss bank account

John Cardone

Foreign Earned Income Exclusion

Withholding & International Individual Compliance

Address taxpayers who have claimed the benefits without meeting the requirement

John Cardone

Verification of Form 1042-S Credit Claimed on Form 1040NR

Withholding & International Individual Compliance

Ensure the amount of withholding credits or refund/credit elect claimed on Forms 1040NR is verified and whether the taxpayer properly reported the income reflected on Form 1042-S

John Cardone

Agricultural Chemicals Security Credit

Eastern Compliance

Ensure taxpayer compliance by verifying that only qualified expenses by eligible taxpayers are considered and that taxpayers are properly defining facilities when computing the credit

Judith McNamara

Deferral of Cancellation of Indebtedness Income

Northeastern Compliance

Ensure taxpayer compliance by verifying that taxpayers who properly deferred cancellation of indebtedness income in 2009/2010 properly report it in subsequent years beginning in 2014

Delon Harris

Energy Efficient Commercial Building Property

Enterprise Activities

Ensure taxpayer compliance with the Energy Efficient Commercial Building Deduction (Section 179D)

Scott Ballint

Section 901 Corporate Direct Foreign Tax Credit

Cross Border Activities

Improve return selection and resource utilization for corporate returns that claim a direct Foreign Tax Credit to focus on taxpayers in an excess limitation position

John Hinding

Section 956 Avoidance

Cross Border Activities

Determine to what extent taxpayer are utilizing cash pooling arrangements and other strategies to improperly avoid the tax consequences of Section 956

John Hinding

Economic Development Incentive

Western Compliance

Ensure taxpayers are not improperly treating government incentives as non-shareholder capital contributions, and excluding them from gross income in claim a tax deduction without offsetting it by the tax credit received

Paul Curtis

Individual Foreign Tax Credit (Form 1116)

Western Compliance

Address taxpayer compliance with the computation of the foreign tax credit limitation of Form 1116

Paul Curtis


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