News & Analysis as of

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

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

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

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

Government Questions the Benefits of IRS Audit Campaigns

McDermott Will & Emery on

On September 28, 2019, the Treasury Inspector General for Tax Administration (TIGTA) issued a report titled Initial Compliance Results Warrant a More Data-Driven Approach to Campaign Issue Selection. As the name of the...more

McDermott Will & Emery

Weekly IRS Roundup August 5 – 9, 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 August 5 – 9, 2019. ...more

McDermott Will & Emery

Is an Increase in LB&I Assertion of Penalties on the Horizon?

On May 31, 2019, the Treasury Inspector General for Tax Administration (TIGTA) released a report indicating that changes may be in the works regarding assertion of accuracy-related penalties in examinations handled by the IRS...more

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