IRS can start asking questions about Campaign Issues. Have your Audit Plan Ready! was published by JD Supra on 12/14/18.
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. The campaigns require strategic planning and deployment of IRS knowledge resources in order to address non-compliance issues. As of October 31, 2018, IRS LBI has identified 50 campaigns:
- 1120-F Delinquent Returns Campaign
- 1120F Interest Expense/Home Office Expense
- Agricultural Chemicals Security Credit Campaign
- Basket Transactions Campaign
- Corporate Direct (Section 901) Foreign Tax Credit (“FTC”)
- Costs that Facilitate an IRC Section 355 Transaction
- Deferral of Cancellation of Indebtedness Income Campaign
- Deferred Variable Annuity Reserves & Life Insurance Reserves IIR Campaign
- Domestic Production Activities Deduction, Multi-Channel Video Program Distributors (MVPD’s) and TV Broadcasters
- Economic Development Incentives Campaign
- Energy Efficient Commercial Building Property Campaign
- F3520/3520-A Non-Compliance and Campus Assessed Penalties
- FATCA Filing Accuracy
- Foreign Base Company Sales Income: Manufacturing Branch Rules
- Foreign Earned Income Exclusion Campaign
- Forms 1042/1042-S Compliance
- Form 1120-F Chapter 3 and Chapter 4 Withholding Campaign
- Form 1120-F Non-Filer Campaign
- Inbound Distributor Campaign
- Individuals Employed by Foreign Governments & International Organizations
- Individual Foreign Tax Credit (Form 1116)
- Individual Foreign Tax Credit Phase II
- IRC 48C Energy Credit Campaign
- IRC Section 199 – Claims Risk Review
- Interest Capitalization for Self-Constructed Assets
- Land Developers – Completed Contract Method (CCM) Campaign
- Micro-Captive Insurance Campaign
- Nonresident Alien Schedule A and Other Deductions
- Nonresident Alien Tax Treaty Exemptions
- NRA Tax Credits
- Offshore Service Providers
- OVDP Declines-Withdrawals Campaign
- Partial Disposition Election for Buildings
- Partnership Stop Filer
- Related Party Transactions Campaign
- Repatriation Campaign
- Repatriation via Foreign Triangular Reorganizations
- Restoration of Sequestered AMT Credit Carryforward
- S Corporation Distributions
- S Corporation Losses Claimed in Excess of Basis Campaign
- Sale of Partnership Interest
- SECA Tax
- Section 956 Avoidance
- Section 965 Transition Tax
- Swiss Bank Program Campaign
- Syndicated Conservation Easement Transactions
- TEFRA Linkage Plan Strategy Campaign
- Verification of Form 1042-S Credit Claimed on Form 1040NR
- Virtual Currency
- Work Opportunity Tax Credit
Issue-Based examinations
The current 50 compliance campaigns present risk and require a response in the form of “one or multiple treatment streams” to achieve compliance objectives via examinations and letters to achieve compliance objectives.
Don’t be a victim of your own making
If you are a Taxpayer with an issue in one of the 50 LBI’s compliance campaigns, consult your tax specialist in order to be ready for an IRS audit.
https://www.jdsupra.com/legalnews/irs-can-start-asking-questions-about-38869/
