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LB&I announces yet another tranche of audit ‘campaigns’

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Tax Hot Topics newsletterThe IRS Large Business and International (LB&I) division announced on Sept. 10 five new compliance campaigns, bringing the total number to 45 since the initiative was rolled out in January 2017.

Campaigns are designed to drive taxpayer compliance through various “treatment streams,” which can include issue-based examinations, soft letters, taxpayer education, published guidance, and other measures taken by the IRS.

The five new campaigns focus on:

  • Section 199 domestic production activities deduction claims
  • Syndicated conservation easement transactions described in Notice 2017-10
  • Foreign base company sales income derived in connection with manufacturing branches
  • Interest expense and home office expense deductions taken on Forms 1120-F, “U.S. Income Tax Return of a Foreign Corporation”
  • Reporting by individuals employed by foreign governments and international organizations

The announcement indicated that as the IRS continues to evaluate the Tax Cuts and Jobs Act, which was enacted in late 2017, it is possible that certain pre-existing campaigns could be impacted.

Contacts
Dave Auclair
National Managing Principal, Washington National Tax Office
T +1 202 521 1515

Liz Askey
Managing Director, Washington National Tax Office
T +1 202 521 1513

Shamik Trivedi
Senior Manager, Washington National Tax Office
T +1 202 521 1511

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