LB&I Add New TCJA Compliance Campaign Including §965 Transition Tax & IRC §962 Election!

On its Active Campaigns website, IRS LB&I has added a new compliance campaign that will examine TCJA issues. This new campaign will examine TCJA issues on a select pool of returns and then share what is learned by these examinations throughout the IRS. 

Issues could include computation of:

IRC §965 Transition Tax,

IRC §250 50% Deduction for Corporate Taxpayer's,
IRC §960 80% Deamed Paid Foreign Tax Credit and
 the IRC §962  election by an Individual to be tax
as a Corporation.

In January 2017, the IRS announced a new audit strategy for its Large Business and International Division (LB&I) known as “compliance campaigns.” With the new compliance campaigns, LB&I essentially shifted to examinations based on compliance issues that LB&I determined presented greater levels of compliance risk, thereby improving return selection. The IRS initially selected 13 compliance issues when it rolled out this strategy. (See IRS Has 13 New Compliance Campaigns for LB&I Taxpayers.)

Since the initial 13 campaign announcement, LB&I has added additional campaigns, see LB&I Has Announced the Approval of 5 Additional Compliance Campaigns (09/14/2018) and LB&I Announces Large Corporate Compliance Program (05/16/2019).

IRS LB&I has added a new The Tax Cuts and Jobs Act (TCJA) campaign on its website

Practice Area: Enterprise Activities
Lead Executive: Nikole Flax
Point of Contact: Monique Gabel

The Tax Cuts and Jobs Act (TCJA) was signed into law on December 22, 2017. Taxpayers have filed returns for 2017 and 2018 and are in the process of preparing and filing 2019 returns.

In 2020, the majority of returns that will be under review by LB&I will be returns reflecting changes brought about by TCJA; and in light of that, LB&I has initiated the TCJA Campaign to closely monitor issues on a select pool of returns and share information learned throughout LB&I and the IRS.

LB&I is also considering the impact of the Coronavirus Aid, Relief and Economic Security (CARES) Act on these returns as well as any others examined. The goal of this campaign is to identify transactions, restructuring and technical issues and better understand taxpayer behavior under the new law.

The treatment streams for this campaign may include examinations, soft letters, outreach, new and improved practice units and development of future issue-based campaigns.

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