What's New:
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Tier I Issues At a Glance - Overview of all Tier I Compliance Issues is now available and can be printed on one page. Additionally, all the same Tier I Issue details are now included in this main Tier I page.
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Quick Reference Guides are now available for all Tier I Compliance Issues - See links next to Issue names below. If you cannot access the hyperlinks in these pdf files, please download the latest version of Adobe Acrobat Reader FREE from the Adobe Reader download page on Adobe's Web site. 05-29-2008
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Former IRS Commissioner Mark W. Everson summarized some of the greatest compliance challenges facing the Large and Mid-Size Business Division (LMSB) in testimony to the Senate Committee on Finance. Those challenges are reflected in the Tier I and Tier II issues.
Tiered Issue Focus Strategy Frequently Asked Questions
New - Tier I Issues At a Glance (pdf)
TIER I COMPLIANCE ISSUES:
§ 118 ABUSE - QUICK REFERENCE GUIDE
Issue Owner - Lavena Williams, Director, Field Operations East, Communications, Technology, and Media
Lead TA - Kathy Follis
Lead Counsel - Anthony Kim
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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118.01-02
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118.01-03
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61.40-02
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Risk Analysis:
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§ 162(f) - GOVERNMENT SETTLEMENTS - QUICK REFERENCE GUIDE
Issue Owner - Sergio Arellano, Industry Director, Retailers, Food, Pharmaceuticals, and Healthcare
Lead TA - John Tucker FCA and Greg Pierce EPA
Lead Counsel - Kirk Chaberski
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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Risk Analysis:
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§ 936 EXIT STRATEGIES – QUICK REFERENCE GUIDE
Issue Owner - Sergio Arellano, Industry Director, Retailers, Food, Pharmaceuticals, and Healthcare
Lead TA - Matt Hartman and Jim Guidone
Lead Counsel - Jim Lanning
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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482.09-00 to
482.11-00
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367.30-00
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Risk Analysis:
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DOMESTIC PRODUCTION DEDUCTION IRC § 199 - QUICK REFERENCE GUIDE
Issue Owner - Charles Brantley, Industry Director, Heavy Manufacturing and Transportation
Lead TA - Sandra Frost and Robert Schnuriger
Lead Counsel - Charles Buxbaum
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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Risk Analysis:
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FOREIGN EARNINGS REPATRIATION - QUICK REFERENCE GUIDE
Issue Owner - Barry B. Shott, Deputy Commissioner, International
Lead TA - Nancy Johnson
Lead Counsel - Glenn McLoughlin
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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Risk Analysis:
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Mandatory if Material - Contact IMT
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FOREIGN TAX CREDIT GENERATORS – QUICK REFERENCE GUIDE
Issue Owner - Walter Harris, Industry Director, Financial Services
Lead TA - Mark English and Linda Azen
Lead Counsel - Marvis Knospe
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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Risk Analysis:
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INTERNATIONAL HYBRID INSTRUMENT TRANSACTIONS – QUICK REFERENCE GUIDE
Issue Owner - Walter Harris, Industry Director, Financial Services
Lead TA - Deborah Childers
Lead Counsel - Steve Tillem
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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Risk Analysis:
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MIXED SERVICE COSTS - QUICK REFERENCE GUIDE
Issue Owner - Keith Jones, Industry Director, Natural Resources and Construction
Lead TA - Frank Genet
Lead Counsel - Marc Shapiro
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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Risk Analysis:
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RESEARCH CREDIT (RC) CLAIMS – QUICK REFERENCE GUIDE
Issue Owner - Lavena Williams, Director, Field Operations East, Communications, Technology, and Media
Lead TA - Lee Keenan
Lead Counsel - Anthony Kim
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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Risk Analysis:
- Audit Team makes risk analysis
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TRANSFER OF INTANGIBLES OFFSHORE/COST SHARING - QUICK REFERENCE GUIDE
Issue Owner - Patricia Chaback, Industry Director, Maria Hwang, Director, Field Operations West, Communications, Technology, and Media
Lead TA - Matt Hartman and Jon Tamaki
Lead Counsel - Michelle Korbas
Industry Director Directives:
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Guidance:
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Key UIL Codes:
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Risk Analysis:
- Audit Team makes risk analysis
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TIER I TAX SHELTER ISSUES - LMSB ISSUE OWNER EXECUTIVE
Distressed Asset/Debt - Larry Barnes, Director, Field Operations East, Heavy Manufacturing and Transportation
Redemption Bogus Optional Basis - Patricia Chaback, Industry Director, Communications, Technology, and Media
Listed Abusive Tax Shelters and Transactions -
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