IRS expands CAP program for compliant taxpayers

Tax Hot Topics newsletterThe IRS Large Business and International (LB&I) division announced on Sept. 12 that it would allow for new applicants to the compliance assurance process (CAP) program.

The CAP program is designed for generally compliant taxpayers, and employs real-time issue resolution through cooperation between the IRS and a taxpayer. Established as a pilot program in 2005, CAP became permanent in 2011. In 2016, the IRS announced that it would no longer accept new applicants. Some taxpayers expressed concern that CAP, which provides an avenue for pre-filing issue resolution by large taxpayers, would come to an end in an era of increasingly strained IRS budgets.

In 2018, the IRS announced that it would accept applications from existing participants, and the latest announcement allows for new applicants. To be eligible to apply for CAP, taxpayers must be publicly traded corporations with audited financial statements, have assets of $10 million or more, and not be under investigation by or in litigation with any government agency that would limit the IRS’s access to current tax records.

David Auclair
National Managing Principal
Washington National Tax Office 
T +1 202 521 1515

Shamik Trivedi
Managing Director
Washington National Tax Office 
T +1 202 521 1511

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