The LB&I IRS audit campaigns are a targeted combination of resources and expertise focused upon 13 separate areas. The IRS Large Business & International Group (LB&I) has established the following teams:
IRC 48C Energy Credit Campaign – This campaign ensures that only those taxpayers whose advanced energy projects were approved by the Department of Energy, and who have been allocated a credit by the IRS, are claiming the credit.
OVDP Declines -Withdrawals Campaign focused upon the Offshore Voluntary Disclosure Program (OVDP) of taxpayers who were either denied access to OVDP or withdrew from the program of their own accord.
Domestic Production Activities Deduction, Multi-Channel Video Program Distributors (MVPD’s) and TV Broadcasters – Multi-channel Video Programing Distributors (MVPDs) and TV Broadcasters often claim that “groups” of channels or programs are a qualified film eligible for the IRC Section 199 deduction.
Micro-Captive Insurance Campaign – Focused upon taxpayer attempts to reduce aggregate taxable income using contracts treated as insurance contracts and a related company that the parties treat as a captive insurance company.
Related Party Transactions Campaign – Focuses on transactions between commonly controlled entities that provide taxpayers a means to transfer funds from the corporation to related pass through entities or shareholders.
Basket Transactions Campaign – Reviewing structured financial transactions in which a taxpayer attempts to defer and treat ordinary income and short-term capital gain as long-term capital gain.
Land Developers – Completed Contract Method (CCM) Campaign – Large land developers that construct in residential communities may be improperly using the Completed Contract Method (CCM) of accounting.
TEFRA Linkage Plan Strategy Campaign – Develops new procedures and technology to work collaboratively with the revenue agent conducting the TEFRA partnership examination to identify, link and assess tax to the terminal investors that pose the most significant compliance risk.
S Corporation Losses Claimed in Excess of Basis Campaign – S corporation shareholders report income, losses and other items passed through from their corporation. The law limits losses and deductions to their basis in the corporation.
Repatriation Campaign – Many US taxpayers do not properly report repatriations as taxable events on their filed returns.
Form 1120-F Non-Filer Campaign – Foreign companies doing business in the U.S. are often required to file Form 1120-F.
Inbound Distributor Campaign – focused upon transfer pricing operations between affiliated companies and ownership groups
Allen Barron represents US taxpayers who have been targeted by the IRS audit campaigns and those who have received IRS notification of audit letters. We will discuss individual LB&I IRS audit campaigns in the coming weeks and months and how US and international companies can protect themselves. We invite you to contact Allen Barron for a free consultation at 866-631-3470. Learn about the protections of the attorney-client privilege and the decades of experience and expertise we can contribute to reduce or eliminate further tax liabilities from an IRS audit.
