News & Analysis as of

Internal Revenue Service Large Business & International Division (LB&I) New Guidance

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
White & Case LLP

The IRS Revamps the Pre-Filing Agreement Program for LB&I Taxpayers

White & Case LLP on

On June 17, 2025, the Internal Revenue Service ("IRS") announced improvements to its Pre-Filing Agreement ("PFA") program. The IRS press release is available here. The PFA program allows Large Business & International...more

McDermott Will & Emery

IRS Hints at Revenue Procedure 94-69 Update

McDermott Will & Emery on

At a recent Tax Executives Institute conference in New York, an Internal Revenue Service (IRS) spokesperson stated that guidance and a new final form will be issued when the IRS and the US Department of the Treasury replace...more

McDermott Will & Emery

IRS Issues Practice Unit on Section 965 Transition Tax

McDermott Will & Emery on

One of the most pressing audit issues for large taxpayers today centers on the Internal Revenue Code (Code) Section 965 transition tax. The Internal Revenue Service (IRS) has designated Code Section 965 as a campaign issue...more

McDermott Will & Emery

Weekly IRS Roundup January 20 – 24, 2020

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 20 – 24, 2020. January 20, 2020: The IRS released new Instructions to IRS Form 1120-S, US...more

McDermott Will & Emery

Weekly IRS Roundup November 18 – 22, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 18 – 22, 2019. November 19, 2019: The IRS published final regulations that affect United...more

McDermott Will & Emery

Weekly IRS Roundup November 4 – 8, 2019

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 4–8, 2019. November 4, 2019: The IRS posted a new Large Business and International...more

McDermott Will & Emery

IRS Issues Transition Tax Compliance Campaign

McDermott Will & Emery on

On November 4, 2019, the Internal Revenue Service (IRS) announced a new Large Business and International (LB&I) compliance campaign regarding Section’s 965 transition tax under the Tax Cuts and Jobs Act (TCJA). This is one of...more

Snell & Wilmer

IRS Amends Program for Offshore Voluntary Disclosures

Snell & Wilmer on

On September 28, 2018, the Internal Revenue Service (IRS) ended its 2014 Offshore Voluntary Disclosure Program (OVDP). The 2014 OVDP (which was an extension of the 2009 and 2011 OVDPs) was meant to allow taxpayers who...more

Eversheds Sutherland (US) LLP

LB&I adds new campaigns on virtual currency and transition tax

On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency and the transition tax...more

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