Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Effective Strategies for Elevating Issues
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more
On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 3, 2023 – January 6, 2023...more
Earlier this year, the Internal Revenue Service (IRS) announced the creation of a new Joint Strategic Emerging Issues Team (JSEIT). The new initiative, announced at the New York University School of Professional Studies Tax...more
In March 2010, Congress codified the economic substance doctrine in Internal Revenue Code (Code) Section 7701(o). The codification clarified that a conjunctive analysis applies in determining if the doctrine applies. The...more
Since 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) has shifted its audit efforts to issue-based examinations, premised on strategically identified and prioritized areas of...more
One of the most pressing audit issues for large taxpayers today centers on the Internal Revenue Code (Code) Section 965 transition tax. The Internal Revenue Service (IRS) has designated Code Section 965 as a campaign issue...more
In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 6, 2020 – July 10, 2020... July 6, 2020: The IRS added new frequently asked questions on...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 18 – May 22, 2020. May 18, 2020: The U.S. Tax Court announced that comments to the...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 4 – May 8, 2020...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 27 – May 1, 2020. April 28, 2020: The IRS published Large Business and International...more
The IRS Large Business and International Division ("LB&I") announced a campaign on February 27, 2020, to examine taxpayers' returns claiming income tax credits and deductions for research expenditures under IRC Sections 41...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 24 – 28, 2020. February 24, 2020: The IRS released final instructions to Form 8978,...more
On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more
On September 28, 2019, the Treasury Inspector General for Tax Administration (TIGTA) issued a report titled Initial Compliance Results Warrant a More Data-Driven Approach to Campaign Issue Selection. As the name of the...more
Earlier this week, the Internal Revenue Service’s Large Business & International Division announced six more compliance campaigns, bringing the total number of campaigns announced to date to a whopping 59. These campaigns...more
On July 19, 2019, the Internal Revenue Service (IRS) Large Business & International (LB&I) division announced the approval of six new campaigns. As in the past, the IRS stated that “LB&I’s goal is to improve return selection,...more
On May 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced changes in, and a new name for, a key compliance program (IR-2019-95) to identify the biggest and most...more
On April 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced three new compliance campaigns. The campaigns focus on: ..Transfer pricing for “captive” services...more
The Internal Revenue Service (IRS) Large Business and International (LB&I) Division continues to churn out new audit “campaigns.” For our prior coverage... The most recent set of campaigns were announced on April 16, 2019,...more
On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more
The Internal Revenue Service (IRS) Large Business and International (LB&I) division recently released an Industry Director’s Directive (IDD) that provides key guidance for life insurers. The IDD is the product of a two-year...more
On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency and the transition tax...more
Yesterday the Internal Revenue Service’s Large Business and International Division announced that it was adding six more compliance campaigns to its previously-announced list of 29 such campaigns. The compliance campaigns...more