2012 |
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08-17-12 |
Tiered Issues |
07-30-12 |
I.R.C. §166: LB&I Directive Related to Partial Worthlessness Deduction for Eligible Securities Reported by Insurance Companies |
03-15-12 |
Large Business & International Directive for Taxpayers who adopted a Method of Accounting Relating to the Conversion of Capitalized Assets to Repair Expense under I.R.C. Section 263(a) |
02-01-12 |
Guidance for Examiners on I.R.C. § 199 Benefits and Burdens of Ownership Analysis in Contract Manufacturing Arrangements |
01-23-12 |
Large Business and International Directive Wireless Telecommunication Assets |
01-23-12 |
Large Business & International Directive Telecommunication Carriers Change in Method of Accounting Relating to Conversion of Capitalized Assets to Repair Expense Under I.R.C. Section 263(a) |
2011 |
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11-25-11 |
Large Business & International Directive Transition Rules for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property |
11-25-11 |
Large Business & International Directive Transition Rules for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property |
11-09-11 |
Consent of Director Provisions for a Voluntary Change in Method of Accounting under Rev. Proc. 2011-14, APPENDIX Section 15.11 |
11-01-11 |
UTP Guidance and Procedures for the Field |
08-31-11 |
UTP Guidance and Procedures for the Compliance Assurance Process (CAP) Program |
07-28-11 |
Examination of Success-Based Fees in the Acquisition of Businesses
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07-15-11 |
Guidance for Examiners and Managers on the Codified Economic Substance Doctrine and Related Penalties |
05-11-11 |
Centralized Management of LB&I Returns with UTP Schedules |
04-14-11 |
I.R.C. §475: Field Directive related to Mark-to-Market Valuation
Frequently Asked Questions for I.R.C. § 475
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03-30-11 |
Industry Director’s Directive # 2—Employment Tax and the Employees on the U.S. Outer Continental Shelf |
03-28-11 |
LB&I Alert - Cases Forwarded to Appeals That Involve a Section 965 Transfer Pricing Adjustment Under Section 482 |
03-01-11 |
Field Guidance on the Planning & Examination of Sales-Based Royalty Payments and Sales-Based Vendor Allowances |
02-23-11 |
Industry Director’s Directive #3 on Super Completed Contract Method |
02-04-11 |
Industry Directive to Withdraw Prior IDD on FSC IRC § 921-927 Bundle of Rights in Software Issue |
2010 |
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12-09-10 |
Tier II Issue - Industry Director Directive #2 on the Proper Treatment of Upfront Fees, Milestone Payments, Royalties and Deferred Income |
11-22-10 |
Tier II Issue – Interchange and Merchant Discount Fees Directive #2 |
09-24-10 |
Field Directive on Treatment of Sales-Based Vendor Allowances (“SBVA”) and Margin Protection Payments (“MPP”) under § 471 |
09-14-10 |
Codification of Economic Substance Doctrine and Related Penalties |
08-09-10 |
Tier III – Field Directive on the Planning and Examination of IRC § 263A issues in the Auto Dealership Industry #2 |
07-26-10
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Directive on Examination Action With Respect to Certain Gain Recognition Agreements
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07-09-10 |
Tier I Issue - IRC § 118 Abuse Directive #9 |
06-16-10 |
Tier I Issue - Loss Importation Transaction - Directive # 1 |
05-20-10 |
Examination of Dividends Received Deduction on Separate Accounts of Life Insurance Companies |
05-13-10
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Use of Delegation Order (DO) 4-25 on Appeals Settlement Position (ASP) for the I.R.C. § 41 Research Credit – Intra-Group Receipts from Foreign Affiliates (IRM 4.46.5.6) |
04-20-10 |
Tier I Issue - Industry Director Directive on Domestic Production Deduction (DPD) #4 |
04-20-10 |
Tier II Issue - Extraterritorial Income Exclusion Effective Date and Transition Rules Directive #1 |
04-12-10 |
Tier II Issue - Specified Liability Losses IRC 172(f) Status Changed to MonitoringIndustry Director Directive #3 |
03-18-10 |
Tier II Issue - Enhanced Oil Recovery Credit IDD #3 |
03-17-10 |
Tier II Issue - Non-Performing Loans Directive #1 |
01-22-10 |
Tier I Issue - Industry Director’s Directive on the Planning and Examination of Repairs vs. Capitalization Change in Accounting Method (CAM) #2 |
01-22-10 |
Tier I Issue - Industry Director’s Directive on the Planning and Examination of Repairs vs. Capitalization Change in Accounting Method (CAM) #1 |
01-14-10 |
Tier I Issue - Industry Directive on Total Return Swaps (“TRSs”) Used to Avoid Dividend Withholding Tax |
2009 |
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12-04-09 |
Tier II Issue - Cost Sharing Stock Based Compensation Directive #2 |
11-03-09 |
Field Directive on the Use of Estimates from Probability Samples |
10-28-09 |
Industry Director Directive #1 on United States Outer Continental Shelf Activity |
10-09-09 |
Tier I Issue - Industry Director Directive #4 on IRC § 936 Exit Strategies |
09-15-09 |
Tier III Issue - Field Directive on the Planning and Examination of IRC § 263A issues in the Auto Dealership Industry |
09-15-09 |
Tier I Issue - Industry Director Directive #5 on Mixed Services Costs |
09-15-09 |
Tier II Issue - Industry Director Directive #2 on Planning and Examination of Contractual Allowances Issues in the Healthcare Industry |
09-15-09 |
Tier II Issue - Industry Director Directive #2 on Super Completed Contract Method |
08-14-09 |
Tier I Issue - Industry Director Directive #3 on IRC § 936 Exit Strategies |
06-19-09 |
Tier II Issue - Industry Director Directive #2 on Specified Liability Loss IRC §172(f) |
06-19-09 |
Tier I Issue - Industry Director Directive #4 on Mixed Service Costs Phase I |
06-19-09 |
Industry Director Directive #2 on Casualty Loss IRC § 165 |
06-04-09 |
Tier I Issue - Industry Director Directive #7 on IRC § 118 Abuse |
06-03-09 |
Tier I Issue - Industry Director Directive #8 on IRC § 118 Abuse |
05-26-09 |
Tier I Issue - Industry Director Directive #3 on IRC § 965 Foreign Earnings Repatriation |
05-22-09 |
Industry Director Directive #2 on International Hybrid Instrument Transactions |
05-14-09 |
Industry Director Directive #2 on Enhanced Oil Recovery Credit |
03-04-09 |
Tier I Issue - Industry Director Directive #3 on Domestic Production Deduction |
02-19-09 |
Tier I Issue - Industry Director Directive on FTC Generator - Revision 1 |
02-09-09 |
Tier I Issue - Industry Director Directive #6 on IRC § 118 Abuse |
01-15-09 |
Tier I Issue - Industry Director Directive #2 on Research Credit Claims Issue |
2008
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11-13-08 |
Tier I Issue - Industry Director Directive #3 on Government Settlements - Revised |
09-15-08 |
Tier I Issue - Industry Director Directive #5 on IRC § 118 Abuse |
08-04-08 |
Tier I Issue - Industry Director Directive #4 on IRC § 118 Abuse |
04-22-08 |
Tier I Issue - Backdated Stock Options Directive #2 |
04-22-08 |
Tier II Issue - Industry Director Directive #1on Interchange and Merchant Discount Fees |
04-21-08 |
Tier I Issue - Foreign Earnings Repatriation Directive #1 |
03-21-08 |
Tier I Issue - Transfer of Intangibles Offshore / IRC § 482 Cost Sharing Buy-in Payment Issue Directive #2 |
02-13-08 |
Tier I Issue - Industry Director Directive #2 on IRC § 936 Exit Strategies |
2007
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10-05-07 |
Industry Directive #3 on IRC § 118 Abuse |
10-02-07 |
Section 965 Foreign Earnings Repatriation (Directive #1) |
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09-14-07 |
Tier I Issue- Government Settlements Directive #2 |
09-10-07 |
Tier II Issue - Planning and Examination of Contractual Allowance Issues in the Healthcare Industry |
08-24-07 |
Domestic Production Deduction |
06-15-07 |
Field Directive #1 on International Hybrid Instrument Transactions |
06-15-07 |
Tier I Issue - Field Directive #1 on Backdated Stock Options |
05-30-07 |
Tier I Issue - Government Settlements Directive #1 |
05-23-07 |
Tier II Issue - Planning and Examination of Gift Card/Certificate Issues in the Retail and Food & Beverage Industries |
05-07-07 |
Tier II Issue - Proper Treatment of Upfr ont Fees, Milestone Payments, Royalties and Deferred Income Upon Entering into a Collaboration Agreement in the Biotech and Pharmaceutical Industries |
05-02-07 |
Tier II Issue - Industry Director Directive on Enhanced Oil Recovery Credit IRC § 43 |
05-02-07 |
Mixed Service Costs (Directive #3) |
05-01-07 |
Mixed Service Costs (Directive #2) |
04-27-07 |
Casualty Loss: Single Identifiable Property/Capital vs. Repairs |
04-24-07 |
IRC § 172(f) Specified Liability Losses |
04-05-07 |
Tier I Issue - Transfer of Intangibles Offshore/ IRC § 482 Cost Sharing Buy-in Payment Issue Directive #1 |
04-04-07 |
Tier I Issue - Research & Experimentation (R&E) Credit Claims Directive #2 |
04-02-07 |
Tier I Issue - IRC § 118 Abuse Directive #2 |
03-13-07 |
Industry Director Directive on Super Completed Contract Method |
02-02-07 |
Tier I Issue - Industry Director Directive on IRC § 936 Exit Strategies |
01-03-07 |
Tier I Issue - Industry Director Directive #1 on IRC § 118 Abuse |
2006
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12-06-06 |
Tier I Issue - Industry Director Directive on Domestic Production Deduction |
07-31-06 |
Industry Director Directive on Deductibility of Casino Complimentary Goods and Services |
07-11-06 |
Industry Director Directive on Asset Class and Depreciation for Casino Construction Costs |
06-08-06 |
Industry Director Directive #1 on Mixed Service Cost |
04-11-06 |
Industry Director Directive on Qualified Intermediary Audit Reports for Audit Years after 2004 |
03-16-06 |
Industry Director Directive on Treatment of Semiconductor Assembly and Test Activities as Manufacturing |
01-13-06 |
Industry Director Directive on Examination of IRC § 847 |
01-12-06 |
Industry Director Directive on Examination of Multiple Parties in Intermediary Transaction Tax Shelters as described in Notice 2001-16 |
2005
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11-28-05 |
Industry Director Directive on the Planning and Examination of Cost Segregation Issues in the Biotech/Pharmaceutical Industry |
08-26-05 |
Industry Director Directive Amended Returns/Refund Claims Containing Invalid IRC § 280(C)(3) Elections |
05-20-05 |
Industry Director Directive Examination of Transaction Costs in the Acquisition of Businesses |
03-14-05 |
Industry Director Directive in Response to Electric Utility Taxpayers' Attempts to Reclassify Utility Property for MACRS Depreciation Purposes |
03-04-05 |
Field Guidance on the Planning and Examination of the Cyclical Overhauls, Betterments, and Rebuilds of Locomotives for Class I Railroads |
03-04-05 |
Field Guidance on the Planning and Examination of the Cyclical Overhauls, Betterments, and Rebuilds of Freight Cars for Class I Railroads |
01-05-05 |
Industry Director Directive on Disposition of Income Forecast Method Issues |
2004
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12-27-04 |
Planning and Examination of Cost Segregation Issues in the Restaurant Industry |
12-16-04 |
Planning and Examination of Cost Segregation Issues in the Retail Industry |
10-12-04 |
IRC Sec. 907 Evaluating Taxpayer Methods of Determining Foreign Oil and Gas Extraction Income (FOGEI) and Foreign Oil Related Income (FORI) |
07-31-04 |
Cost Depletion - Determination of Recoverable Reserves |
04-30-04 |
Planning and Examination of Research Credit Issues in a Branded Pharmaceutical Company |
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04-16-04 |
Timber Casualty Losses |
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° Exhibit A - Timber Casualty Loss Audit Techniques Guide
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° Exhibit B - Issue Paper on Timber Casualty Losses - Valuation of a Single Identifiable Property
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02-02-04 |
IRC § 29 Credits Claimed on Solid Synthetic Fuel from Coal - Significant Chemical Change Issue |
01-12-04 |
Stock Options and Cost Sharing Agreements |
2003
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11-14-03
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Foreign Sales Corporations (FSC) IRC § 921-927 Bundle of Rights in Software Issue |
10-31-03
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Examination of Forms 1042 |
10-24-03
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Examination Procedures for Sports Franchise Acquisitions |
10-24-03
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Examination of Sports Franchise Acquisitions |
10-17-03
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Examination of Legally Mandated Research and Experimentation Expenses in the Biotech and Pharmaceutical Industries |
06-02-03
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Qualified Intermediary Audit Reports for Audit Years Before 2005 |
03-24-03
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Planning and Examination of Construction "Tenant" Allowances for Leases Greater Than 15 Years |
03-14-03
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Assertion of the Penalty for Failure to Deposit Employment Taxes |
03-07-03
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Asset Class and Depreciation for Casino Construction Costs |
03-07-03
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Audit Procedures to Determine Recovery Period of Various Components of a Casino/Hotel Complex |
01-21-03
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Planning and Examination of Research Credit - Generic Drugs |
2002
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10-16-02
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Planning and Examination of Developer Inducements |
04-26-02
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Guidelines for Intangibles Under IRC § 263(a) |
04-08-02
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MACRS Asset Categories for Refinery Assets |
02-26-02
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Guidelines for the Application of Advance Notice of Rulemaking for Intangibles Under IRC § 263(a) |
02-25-02
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Audit Procedures for Golf Course Land Improvements - Change in Accounting Method |
02-07-02
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Depreciable Golf Course Land Improvements and the Impact of Rev. Rul. 2001-60 |
2001
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12-12-01
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Conformity Election for Bank Bad Debts |
06-08-01
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Field Guidance on the Planning and Examination of the Heavy Maintenance Visit (HMV) on Airframes |