Large Business and International compliance campaigns Campaigns will ensure that resources are used efficiently and effectively to improve taxpayer compliance. LB&I's goal is to improve return selection, identify issues representing the risk of non-compliance, and make the greatest use of limited resources. Large Business and International Examination Process Publication 5125 provides an overview of the Large Business and International (LB&I) Examination Process (LEP), from the first contact with the taxpayer through the final stage of issue resolution. LB&I Fiscal Year 2024 Focus Guide LB&I releases the FY 2024 Focus Guide with a message from LB&I Commissioner Holly O. Paz laying out the operational goals for FY 2024. Qualified Intermediary Program Use the IRS QI/WP/WT System to apply, renew or terminate your status as a Qualified Intermediary, Withholding Foreign Partnership or Withholding Foreign Trust. Abusive tax shelters and transactions The Internal Revenue Service has a comprehensive strategy in place to combat abusive tax shelters and transactions. This strategy includes guidance on abusive transactions, regulations governing tax shelters, a hotline for taxpayers to use to report abusive technical transactions, and enforcement activity against abusive tax shelter promoters and investors. Corporate executive compliance The Internal Revenue Service is taking steps to improve tax compliance by corporations and their executive employees. One area of emphasis is executive compensation, for which audit technique guides have been developed for use by agents in examining tax returns filed by corporations and executives. E-file for large business and international (LB&I) Certain large business and international (LB&I) corporations are required to electronically file their Forms 1120 and 1120-S. Other corporations may do so voluntarily. This site provides e-file information for corporations that prepare and transmit their own electronic corporate income tax returns and those that use the services of third party tax professionals. FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes FIN 48 is intended to eliminate inconsistency in accounting for uncertain tax positions in financial statements certified in accordance with U.S. GAAP and mandates new rules for recognition, de-recognition, measurement, and disclosure of tax positions. Filing Requirements for Filing Status Change Guidance for taxpayers requesting to change their filing status from a C Corporation (filing Form 1120) to an S Corporation (filing Form 1120S). Foreign Account Tax Compliance Act (FATCA) The Foreign Account Tax Compliance Act (FATCA) requires certain U.S. taxpayers holding financial assets outside the country to report those assets to the IRS. Form 8806 published filers Corporations must file Form 8806, Information Return for Acquisition of Control or Substantial Change in Capital Structure, with the IRS to report an acquisition of control or substantial change in capital structure, as defined in the regulation. Industry Issue Resolution Program The Industry Issue Resolution (IIR) Program resolves frequently disputed or burdensome tax issues. IRS solicits suggestions for issues for the program from taxpayers, representatives and associations. International Businesses International Businesses list. The international tax gap Find resources on this page on the international tax gap — the difference between the amount of tax that taxpayers should pay and the amount that is paid voluntarily and on time. The tax gap can also be thought of as the sum of non-compliance with the tax law. LBI Technical Resources and Guidance Coordinated issue papers, Industry Director guidance, audit technique guides and other documents provide technical information and guidance on complex tax law and administrative issues affecting the LB&I division and LB&I taxpayers. Pre-Filing Agreement Program The Pre-Filing Agreement Program is expected to reduce taxpayer burden and make more effective use of IRS resources by resolving or eliminating tax controversy earlier in the examination process. Report of Foreign Bank and Financial Accounts (FBAR) You may be required to report yearly to the IRS foreign bank and financial accounts (FBAR) exceeding certain thresholds. S corporations By electing to be treated as an S corporation, an eligible domestic corporation can avoid double taxation. Schedule M-3 for Large Business & International (LB&I) Schedule M-3 is used by certain corporations and partnerships to reconcile financial accounting net income and taxable income. Affected corporations and partnerships are those with assets of $10 million or more that file Form 1120, 1120-PC, 1120-L, 1120S, or 1065. Certain other partnerships filing Form 1065 are also required to use the Schedule M-3. Uncertain tax positions - Schedule UTP IRS finalized Schedule UTP & instructions for reporting uncertain tax positions by certain corporations. Compliance Assurance Process (CAP) Large Business and International (LB&I) Division developed the CAP to improve the federal tax compliance of large corporate taxpayers. CAP uses real-time issue resolution tools and techniques. In CAP, the IRS and taxpayer work together to achieve tax compliance by resolving issues before the taxpayer files their tax return. Successful conclusion of CAP allows the IRS to achieve an acceptable level of assurance on the accuracy of the taxpayer’s filed tax return and to substantially shorten the length of the post filing examination. Large Corporate Compliance Program (LCC) The Large Corporate Compliance (LCC) program focuses on noncompliance by using data analytics to identify large corporate taxpayers to audit. Corporations Topics Large Business and International division at a glance Large Business & International Directives Tax code, regulations, and official guidance Corporations Preventing and Resolving Disputes
LB&I Fiscal Year 2024 Focus Guide LB&I releases the FY 2024 Focus Guide with a message from LB&I Commissioner Holly O. Paz laying out the operational goals for FY 2024.
Industry Issue Resolution Program The Industry Issue Resolution (IIR) Program resolves frequently disputed or burdensome tax issues. IRS solicits suggestions for issues for the program from taxpayers, representatives and associations.
Compliance Assurance Process (CAP) Large Business and International (LB&I) Division developed the CAP to improve the federal tax compliance of large corporate taxpayers. CAP uses real-time issue resolution tools and techniques. In CAP, the IRS and taxpayer work together to achieve tax compliance by resolving issues before the taxpayer files their tax return. Successful conclusion of CAP allows the IRS to achieve an acceptable level of assurance on the accuracy of the taxpayer’s filed tax return and to substantially shorten the length of the post filing examination.
Large Corporate Compliance Program (LCC) The Large Corporate Compliance (LCC) program focuses on noncompliance by using data analytics to identify large corporate taxpayers to audit.