October 2018 Foodman CPAs & Advisors

IRS Large Business and International (IRS LBI) currently has 59 Active Compliance Campaigns.  The purpose of the IRS compliance campaign strategy is 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.

The campaigns are:

  1. 1120-F Delinquent Returns Campaign
  2. 1120F Interest Expense/Home Office Expense
  3. Agricultural Chemicals Security Credit Campaign
  4. Basket Transactions Campaign
  5. Corporate Direct (Section 901) Foreign Tax Credit (“FTC”)
  6. Costs that Facilitate an IRC Section 355 Transaction
  7. Deferral of Cancellation of Indebtedness Income Campaign
  8. Deferred Variable Annuity Reserves & Life Insurance Reserves IIR Campaign
  9. Domestic Production Activities Deduction, Multi-Channel Video Program Distributors (MVPD’s) and TV Broadcasters
  10. Economic Development Incentives Campaign
  11. Energy Efficient Commercial Building Property Campaign
  12. F3520/3520-A Non-Compliance and Campus Assessed Penalties
  13. FATCA Filing Accuracy
  14. Foreign Base Company Sales Income: Manufacturing Branch Rules
  15. Foreign Earned Income Exclusion Campaign
  16. Forms 1042/1042-S Compliance
  17. Form 1120-F Chapter 3 and Chapter 4 Withholding Campaign
  18. Form 1120-F Non-Filer Campaign
  19. Inbound Distributor Campaign
  20. Individuals Employed by Foreign Governments & International Organizations
  21. Individual Foreign Tax Credit (Form 1116)
  22. Individual Foreign Tax Credit Phase II
  23. IRC 48C Energy Credit Campaign
  24. IRC Section 199 – Claims Risk Review
  25. Interest Capitalization for Self-Constructed Assets
  26. Land Developers – Completed Contract Method (CCM) Campaign
  27. Micro-Captive Insurance Campaign
  28. Nonresident Alien Schedule A and Other Deductions
  29. Nonresident Alien Tax Treaty Exemptions
  30. NRA Tax Credits
  31. Offshore Service Providers
  32. OVDP Declines-Withdrawals Campaign
  33. Partial Disposition Election for Buildings
  34. Partnership Stop Filer
  35. Related Party Transactions Campaign
  36. Repatriation Campaign
  37. Repatriation via Foreign Triangular Reorganizations
  38. Restoration of Sequestered AMT Credit Carryforward
  39. S Corporation Distributions
  40. S Corporation Losses Claimed in Excess of Basis Campaign
  41. Sale of Partnership Interest
  42. SECA Tax
  43. Section 956 Avoidance
  44. Section 965 Transition Tax
  45. Swiss Bank Program Campaign
  46. Syndicated Conservation Easement Transactions
  47. TEFRA Linkage Plan Strategy Campaign
  48. Verification of Form 1042-S Credit Claimed on Form 1040NR
  49. Virtual Currency
  50. Work Opportunity Tax Credit
  51. Captive Services Provider Campaign
  52. Offshore Private Banking Campaign
  53. Loose Filed Forms 5471

On July 19, 2019, IRS LBI approved an additional 6 campaigns:

  1.  S Corporations Built in Gains Tax
  2. Post OVDP Compliance
  3. Expatriation
  4. High Income Non-filer
  5. U.S. Territories – Erroneous Refundable Credits
  6. Section 457A Deferred Compensation Attributable to Services Performed before January 1, 2009

Issue-Based examinations

The current 59 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 59 LBI’s compliance campaigns, consult your tax specialist in order to be ready for an IRS audit.