Jones Day Presents: Large Business & International Examination Strategies: Fast Track Settlements
Jones Day Presents: LB&I Examination Strategies: Effective Strategies for Elevating Issues
Jones Day Presents: LB&I Examination Strategies: Acknowledgement of Facts IDR
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures. Specifically, the IGM (1) removes the...more
Tax developments - IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs - Significant updates from the IRS Large Business & International (LB&I) Division will take...more
The IRS has issued new guidance to its Large Business and International Division (LB&I) in an attempt to expedite audits. The interim guidance, released on July 23, 2025, outlines procedural changes that will further...more
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
A recent memo from the IRS's Large Business and International (LB&I) Division indicates an intention to resolve audits efficiently and provide taxpayers with opportunities to quickly settle and resolve issues....more
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
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
IRS LB&I has updated several pieces of administrative guidance, including a notice regarding the transition period for complying with increased substantiation requirements for research credit refund claims and two practice...more
The rules relating to delegated authority are complex. A taxpayer is well advised to ensure that the scope of a closing agreement the taxpayer signs is what the taxpayer expects, and that an IRS official who signs the...more
Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more
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
On February 21, 2024, the Internal Revenue Service (IRS) announced a new initiative to audit the use of airplanes by corporations, large partnerships and high-net-worth individuals. While the IRS has always examined plane...more
On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more
The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more
Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more
The IRS announced a "sweeping" and "historic" enforcement effort focused on partnerships and is establishing a special group within its Large Business and International (LB&I) Division to focus exclusively on large and...more
Back in October 2021, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) division announced the Large Partnership Compliance (LPC) program. This new audit program adopted features of the Large...more
The Economic Crime and Corporate Transparency Bill is to introduce new powers for UK authorities to prosecute organizations for failing to prevent fraud committed by their agents, or employees. Championed as a “game changer”...more
The Internal Revenue Service’s (IRS) Large Business and International (LB&I) Division updated its list of Active Campaigns, which includes more than 50 efforts to increase tax compliance. Each campaign identifies the practice...more
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
As part of the European Commission’s (EC’s) commitment to strengthen sustainability disclosure in its 2018 Sustainable Finance Action Plan, the EC, together with the European Financial Reporting Advisory Group (EFRAG), has...more
The Rixain Law of December 24, 2021 introduces an obligation of balanced representation between women and men in the management positions of large companies...more
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
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
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