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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