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.
