IRS expands list of large business audit 'campaigns'

According to the IRS, the goal of this campaign is to determine the extent to which taxpayers are using cash-pooling arrangements and other strategies to avoid Sec. 956 inclusions. Taxpayers eligible to receive certain government economic incentives may receive tax benefits in the form of refundable credits, tax credits against other business taxes, nonrefundable credits, transfer of property including land, and grants including cash payments. By comparison, the IRS's first 13 issues focused on the following: * Sec. 48C energy credit; * Declines and withdrawals of the OVDP; * Sec. 199 domestic production activities deduction (DPAD) deductions by multichannel video program distributors and TV broadcasters; * Micro-captive insurance arrangements; * Related-party transactions between commonly controlled entities; * Deferred variable annuity reserves and life insurance reserves; * Basket transactions; * Land developers and the completedcontract method; * Tax Equity and Fiscal Responsibility Act linkage; * S corporation losses claimed in excess of basis; * Repatriation of foreign earnings for middle-market taxpayers; * Form 1120-F nonfilers; and * Inbound distributors. [...]it is incumbent on taxpayers and their advisers to be certain of the appropriate examination procedures currently in place by LB&I. The author thanks DavidAuclair and LizAskey for their counsel with this item.