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
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
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
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
The Internal Revenue Service (IRS), through its Large Business and International Division (LB&I), has created a Global High Wealth (GHW) program to audit hundreds of high-wealth taxpayers who own assets or earnings in the...more
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
Taxpayers typically incur significant transaction costs when undergoing a transaction involving a restructuring, acquisition, disposition, sale of assets, or sale of stock. The default rule under section 263 is that all...more
The Large Business and International Division of the Internal Revenue Service (IRS) developed the Compliance Assurance Process (CAP) program to improve large corporate taxpayer compliance with US federal tax obligations...more
In the fourth installment of Jones Day’s series of video presentations on the IRS's Large Business & International Division ("LB&I") exam procedures, partner and tax litigator Chuck Hodges explains how the IRS’s new process...more
In the second installment of Jones Day’s video series on the IRS's Large Business & International Division ("LB&I") exam process, partner and tax litigator Chuck Hodges discusses changes in how the division issues Information...more
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