IRS Launches 13 Issue-Based Corporate Compliance Campaigns
February 6, 2017 by Mark D. Allison, J. Clark Armitage, Kirsten Burmester, Niles A. Elber, Neal M. Kochman, Rachel L. Partain, Charles M. Ruchelman, James E Salles, Zhanna Ziering and Dustin J. Barzell
On January 31, 2017, the Internal Revenue Service (IRS) launched its first wave of compliance “campaigns.” A campaign is an issue-based compliance process centering on focused examinations, staffed with IRS experts on the targeted subject matter. The 13 identified campaigns (click here to access more information) cover a broad range of topics, including TEFRA partnerships, micro-captive insurance transactions, transfer pricing, repatriation of foreign earnings, and offshore voluntary disclosure. Working through the Large Business and International division (LB&I), the IRS will deploy resources to investigate and remediate these issues through one or more “treatment steams.” This new issue-focused approach means businesses and high-net-worth individuals dealing with any of the identified issues face increased IRS audit risk, and should work with their legal advisors to prepare for IRS challenges of their positions. In this alert, for each of the 13 campaigns, we identify the targeted issue(s), explain the IRS strategy, provide relevant insights for how the campaign will impact taxpayers, and identify Caplin lawyers with experience in the area.
...Click HERE for the full story via Mondaq…
6. Deferred Variable Annuity Reserves & Life Insurance Reserves IIR
This is an industry issue resolution initiative, not an enforcement initiative, to provide guidance on life insurance companies’ reserve computations that will be accepted for federal income tax purposes. This project is driven in part by the emergence for state regulatory purposes of stochastic methods of computing risk-based capital, as contrasted with the traditional state-law methods of computing life insurance reserves that are reflected in the provisions of Part I of Subchapter L of the Internal Revenue Code.
For more information, please contact Richard W. Skillman.
