Coordinated Issue Papers - LMSB
A major objective of the IRS Large and Mid-Size Business Division's Issue Management Strategy is to identify, coordinate and resolve complex and significant industry wide issues by providing guidance to field examiners and ensuring uniform application of the law. Uniformity is achieved through the issuance of coordinated issue papers, which, following review by the Office of Chief Counsel, are issued by the Commissioner, Large and Mid-Size Business Division. Although these papers are not official pronouncements on the issues, they do set forth the Service's current thinking.
ALL INDUSTRIES (Cross All Industry Lines)
INSURANCE, BLUE CROSS BLUE SHIELD/HEALTH INSURANCE
SAVINGS & LOAN
SECURITIES & FINANCIAL SERVICE FIRMS
COORDINATED ISSUES - LISTED TRANSACTIONS
Internal Revenue Manual (IRM) 4.51.2 provides that a listed transaction will be treated as a coordinated issue as of the date the listing notice is issued. A listed transaction is one that the IRS has determined to be structured for the significant purpose of tax avoidance or evasion. A memorandum from the responsible IRS Division Commissioner will be issued regarding the coordination of the issue, and a coordinated issue paper will be prepared and issued at a later date.
Page Last Reviewed or Updated: February 05, 2009