News & Analysis as of

Internal Revenue Service Large Business & International Division (LB&I) Tax Returns

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.  
Eversheds Sutherland (US) LLP

IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs

On July 25, 2025, the IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (Control Number: LB&I-04-0725-0008) implementing changes for LB&I audit procedures, which take effect August 1,...more

Eversheds Sutherland (US) LLP

IRS re-commits to pre-filing agreements

On June 17, 2025, the Internal Revenue Service (IRS) announced improvements to its pre-filing agreement (PFA) program. The PFA program aims to enable taxpayers and the IRS to resolve issues, which would likely appear in a...more

White & Case LLP

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

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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

Kohrman Jackson & Krantz LLP

IRS Cracks Down on High-Income Earners

Since the Internal Revenue Service (IRS) has received its supplemental funding under the Inflation Reduction Act, the IRS has continuously focused on high-income earners, partnerships, and large corporations. Under its most...more

McDermott Will & Emery

Weekly IRS Roundup January 3 – January 6, 2023

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 3, 2023 – January 6, 2023...more

McDermott Will & Emery

Weekly IRS Roundup October 10 – October 14, 2022

McDermott Will & Emery on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 10, 2022 – October 14, 2022...more

McDermott Will & Emery

IRS Official Provides Update on Large Partnership Compliance Audits

McDermott Will & Emery on

Almost 11 months ago, the Internal Revenue Service (IRS) released a memorandum regarding the implementation of the Large Partnership Compliance (LPC) Pilot Program, including the identification, selecting and delivery of...more

McDermott Will & Emery

Special IRS Team Working to Identify Emerging “Abusive Transactions”

Earlier this year, the Internal Revenue Service (IRS) announced the creation of a new Joint Strategic Emerging Issues Team (JSEIT). The new initiative, announced at the New York University School of Professional Studies Tax...more

McDermott Will & Emery

Weekly IRS Roundup October 18 – October 22, 2021

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 18, 2021 – October 22, 2021... October 18, 2021: The IRS announced that beginning...more

Holland & Knight LLP

When Is a Tax Return "Filed"?

Holland & Knight LLP on

In Notice 2004-45, 2004-2 C.B. 33, the IRS put taxpayers who were asserting to be bona fide residents of the U.S. Virgin Islands (USVI) and who were not following the requirements of meeting the applicable bona fide residency...more

Bowditch & Dewey

IRS Discusses New IRS Return Examination Campaigns

Bowditch & Dewey on

In remarks at the NYU Tax Controversy Forum in June, the IRS discussed two new IRS return examination campaigns. Ms. Tamera Ripperda, the commissioner of the Tax Exempt and Government Entities (TEGE) Division who previously...more

Miller Canfield

IRS Announces Updates to Income Tax Credits for Research Expenditures

Miller Canfield on

The IRS Large Business and International Division ("LB&I") announced a campaign on February 27, 2020, to examine taxpayers' returns claiming income tax credits and deductions for research expenditures under IRC Sections 41...more

McDermott Will & Emery

More IRS “Campaigns?! IRS Announces Six More Examination Campaigns

McDermott Will & Emery on

On July 19, 2019, the Internal Revenue Service (IRS) Large Business & International (LB&I) division announced the approval of six new campaigns. As in the past, the IRS stated that “LB&I’s goal is to improve return selection,...more

Jones Day

Jones Day Presents: LB&I Examination Strategies: Process Overview

Jones Day on

In 2016, the IRS's Large Business & International (LB&I) Division significantly altered its examination processes. In the first in a series of programs on LB&I strategies, Jones Day partner and tax litigator Chuck Hodges...more

Eversheds Sutherland (US) LLP

Large corporate compliance program announced by LB&I

On May 16, 2019, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced changes in, and a new name for, a key compliance program (IR-2019-95) to identify the biggest and most...more

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