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LB&I Directives

LB&I Directives provide administrative guidance to LB&I examiners to ensure consistent tax administration and on matters relating to internal operations. The Directives do not establish Service position on legal issues and are not legal guidance. 

LB&I (formerly LMSB) Directives

 
2014
11-21-14 Withdrawal of Directive LMSB-4-0510-017
10-24-14 LB&I Directive Related to § 166 Deductions for Eligible Debt and Eligible Debt Securities
10-14-14 Allocating Mixed Service Costs Under I.R.C. Section 263A to Certain Self-Constructed Property of Electric and Natural Gas Utilities
09-03-14 Large Business & International Directive Extending Transition Rules and the Scope Limitation Waiver for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property-LB&I Directive #3
07-17-14 I.R.C. §446: LB&I Directive for Hedging of Variable Annuity Guaranteed Minimum Benefits (GMxB) by Insurance Companies
03-18-14 LB&I Directive for the Use of MFT C6 on FBAR Examination Cases
02-28-14 Large Business and International Directive on Information Document Requests Enforcement Process
01-27-14 Updated Guidance on the Examination of Milestone Payments in the Acquisition of Businesses
01-21-14 De-coordination of All LB&I Coordinated Issue Papers
2013  
11-04-13 Large Business and International Directive on Information Document Requests Enforcement Process
10-29-13 Updated Guidance for Examiners on I.R.C. § 199 Benefits and Burdens of Ownership Analysis in Contract Manufacturing Arrangements
07-24-13 Guidance for Examiners on I.R.C. § 199 Benefits and Burdens of Ownership Analysis in Contract Manufacturing Arrangements
06-18-13 Large Business & International on Information Document Requests (IDRs)
06-10-13 Large Business & International Directive for Taxpayers Changing to the Method of Accounting Provided in Rev. Proc. 2013-24 for Steam or Electric Generation Property
05-02-13 Extension of Transition Rules for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property - LB&I Directive #2
04-29-13 Examination of Milestone Payments in the Acquisition of Businesses
03-22-13 UPDATED LB&I 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)
2012  
12-07-12 Railroad Industry Capitalization Issues Impacted by the March 15, 2012, Stand Down Directive (LB&I-4-0312-004) Released after the Temporary Tangible Regulations were Issued December 23, 2011
12-07-12 Guidance for Computing and Substantiating the Credit for Increasing Research Activities under Section 41 of the Internal Revenue Code for Activities involved in Developing New Pharmaceutical Drugs and Therapeutic Biologics
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 LB&I Directive for TPs who adopted a Method of Accounting Relating to the Conversion of Capitalized Assets to Repair Expense under I.R.C. § 263(a)
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  
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
 
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

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
02-04-11 Industry Directive to Withdraw Prior IDD on FSC IRC § 921-927 Bundle of Rights in Software Issue
2010  
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
05-20-10 Examination of Dividends Received Deduction on Separate Accounts of Life Insurance Companies

05-13-10

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)
2009  
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

2006

 
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
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

 
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

 
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
 
 
 
 
04-16-04 Timber Casualty Losses
 

° Exhibit A - Timber Casualty Loss Audit Techniques Guide

 

° Exhibit B - Issue Paper on Timber Casualty Losses - Valuation of a Single Identifiable Property

02-02-04 IRC § 29 Credits Claimed on Solid Synthetic Fuel from Coal - Significant Chemical Change Issue

2003

 

11-14-03

Foreign Sales Corporations (FSC) IRC § 921-927 Bundle of Rights in Software Issue

10-24-03

Examination Procedures for Sports Franchise Acquisitions

10-24-03

Examination of Sports Franchise Acquisitions

10-17-03

Examination of Legally Mandated Research and Experimentation Expenses in the Biotech and Pharmaceutical Industries

06-02-03

Qualified Intermediary Audit Reports for Audit Years Before 2005

03-24-03

Planning and Examination of Construction "Tenant" Allowances for Leases Greater Than 15 Years

03-14-03

Assertion of the Penalty for Failure to Deposit Employment Taxes

03-07-03

Asset Class and Depreciation for Casino Construction Costs

03-07-03

Audit Procedures to Determine Recovery Period of Various Components of a Casino/Hotel Complex

01-21-03

Planning and Examination of Research Credit - Generic Drugs

2002

 

10-16-02

Planning and Examination of Developer Inducements

04-26-02

Guidelines for Intangibles Under IRC § 263(a)

04-08-02

MACRS Asset Categories for Refinery Assets

02-26-02

Guidelines for the Application of Advance Notice of Rulemaking for Intangibles Under IRC § 263(a)

02-25-02

Audit Procedures for Golf Course Land Improvements - Change in Accounting Method

02-07-02

Depreciable Golf Course Land Improvements and the Impact of Rev. Rul. 2001-60

2001

 

12-12-01

Conformity Election for Bank Bad Debts

06-08-01

Field Guidance on the Planning and Examination of the Heavy Maintenance Visit (HMV) on Airframes
Page Last Reviewed or Updated: 25-Nov-2014