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Tax Information For Corporations

LB&I Compliance Campaigns
LB&I launches Compliance Campaigns. Campaigns will ensure that resources are used efficiently and effectively to improve taxpayer compliance. LB&I's goal is to improve return selection, identify issues representing the risk of non-compliance, and make the greatest use of limited resources.

Publication 5125, LB&I Examination Process
After collaboration between LB&I and key stakeholder groups and extensive input from the LB&I workforce, Publication 5125, LB&I Examination Process, is now available. Publication 5125 will be replacing Publication 4837, Achieving Quality Examinations through Effective Planning, Execution and Resolution, effective for cases starting as of May 1, 2016.

LB&I Fiscal Year 2017 Focus Guide
LB&I releases the FY2017 Focus Guide with a message from LB&I Commissioner Douglas W. O'Donnell laying out the operational goals for FY 2017.

Abusive Tax Shelters and Transactions
The Internal Revenue Service has a comprehensive strategy in place to combat abusive tax shelters and transactions. This strategy includes guidance on abusive transactions, regulations governing tax shelters, a hotline for taxpayers to use to report abusive technical transactions, and enforcement activity against abusive tax shelter promoters and investors.

If you disagree with the results of an audit or IRS Collection actions, you may have the right to an appeal.

Corporate Executive Compliance
The Internal Revenue Service is taking steps to improve tax compliance by corporations and their executive employees. One area of emphasis is executive compensation, for which audit technique guides have been developed for use by agents in examining tax returns filed by corporations and executives.

e-file for Large Business and International (LB&I)
Certain large business and International (LB&I) corporations are required to electronically file their Forms 1120 and 1120S. Other corporations may do so voluntarily. This site provides e-file information for corporations that prepare and transmit their own electronic corporate income tax returns and those that use the services of third party tax professionals.

FASB Interpretation No. 48, "Accounting for Uncertainty in Income Taxes"
FIN 48 is intended to eliminate inconsistency in accounting for uncertain tax positions in financial statements certified in accordance with U.S. GAAP and mandates new rules for recognition, de-recognition, measurement, and disclosure of tax positions.

Fast Track Settlement
The LB&I / Appeals Fast Track Settlement program is a joint effort between the Large Business and International (LB&I) Division and Appeals to use the mediation skills and delegated settlement authority of Appeals to resolve issues while still under LB&I jurisdiction.

Filing Requirements for Filing Status Change (revised 11-15-11)
Guidance for taxpayers requesting to change their filing status from a C Corporation (filing Form 1120) to an S Corporation (filing Form 1120S).

Foreign Account Tax Compliance Act
FATCA will increase information reporting by foreign financial institutions, non-financial foreign entities, and certain U.S. persons holding financial assets outside the United States.

Forms 5471 - Automatic Assessment of Penalties under IRC Section 6038(b)(1)
Beginning January 1, 2009, the Internal Revenue Service Center will automatically assert appropriate penalties on late filed Forms 1120 with Forms 5471 attached. Taxpayers are encouraged to submit delinquent Forms 5471 prior to January 1, 2009.

Form 8806 - Information Return for Acquisition of Control or Substantial Change in Capital Structure
Pursuant to the provisions of Temporary Regulation § 1.6043-4T(a), requiring reporting of certain acquisitions of control and substantial changes in capital structure, corporations can consent to the publication by the IRS of the information from their Form 8806.

Income from Abroad is Taxable
There have been recent reports about the interest of the Internal Revenue Service (IRS) in taxpayers with bank accounts in Liechtenstein. The IRS' interest, however, extends beyond bank accounts in Liechtenstein to financial accounts anywhere in the world. The IRS reminds you to report your worldwide income on your U.S. tax return and lists the possible consequences of hiding income overseas.

Industry Issue Resolution Program
The Industry Issue Resolution (IIR) Program resolves frequently disputed or burdensome tax issues. IRS solicits suggestions for issues for the program from taxpayers, representatives and associations.

International Businesses
Provides links to information on a variety of International topics including Tax Treaties, Know-Your-Customer (KYC) Rules, Transfer Pricing and Qualified Intermediaries (QI).

Application of Posted 1065 FAQ Answers to Similar Form 1120 Questions
Posted 1065 FAQ answers regarding ownership reporting for Form 1065 Schedule B questions 3 and 4 may be applied to similar issues in reporting ownership for Form 1120 Schedule K questions 4 and 5. Both sets of questions require a limited application of section 267(c) attribution rules to determine total ownership percentages, direct or indirect.

The International Tax Gap
Find resources on this page pertaining to the international tax gap — the difference between the amount of tax that taxpayers should pay and the amount that is paid voluntarily and on time. The tax gap can also be thought of as the sum of non-compliance with the tax law.

LB&I Technical Resources and Guidance
Coordinated issue papers, Industry Director guidance, audit technique guides and other documents provide technical information and guidance on complex tax law and administrative issues affecting the LB&I division and LB&I taxpayers.

Pre-Filing Agreement Program
The Pre-Filing Agreement Program is expected to reduce taxpayer burden and make more effective use of IRS resources by resolving or eliminating tax controversy earlier in the examination process.

Quality Examination Process
The Quality Examination Process (QEP) is a systematic approach for engaging and involving Large Business and International (LB&I) taxpayers in the tax examination process, from the earliest planning stages through resolution of all issues and completion of the case.

Report of Foreign Bank and Financial Accounts (FBAR)
If you own a foreign bank account, brokerage account, mutual fund, unit trust, or other financial account, then you may be required to report the account yearly to the Internal Revenue Service.

S Corporations
An eligible domestic corporation can avoid double taxation (once to the shareholders and again to the corporation) by electing to be treated as an S corporation.

Schedule M-3 for Large Business & International (LB&I)
Schedule M-3 is used by certain corporations and partnerships to reconcile financial accounting net income and taxable income. Affected corporations and partnerships are those with assets of $10 million or more that file Form 1120, 1120-PC, 1120-L, 1120S, or 1065. Certain other partnerships filing Form 1065 are also required to use the Schedule M-3.

2008 Changes to Form 1065 - Frequently Asked Questions
Posted 1065 FAQ answers regarding ownership reporting for Form 1065 Schedule B questions 3 and 4 may be applied to similar issues in reporting ownership for Form 1120 Schedule K questions 4 and 5. Both sets of questions require a limited application of section 267(c) attribution rules to determine total ownership percentages, direct or indirect.

U.S./Germany Tax Treaty Modified to Include Mandatory Arbitration in Certain Circumstances
A new Protocol modifying certain provisions of the income tax treaty between the U.S. and Germany came into force on Dec. 28, 2007. It modifies Article 25 Mutual Agreement Procedure (MAP) to provide for mandatory arbitration of certain cases in the MAP. This announcement provides interim guidance for the “commencement date” for MAP case arbitration until a formal mutual agreement is published.

Uncertain Tax Positions - Schedule UTP
IRS finalized Schedule UTP & instructions for reporting uncertain tax positions by certain corporations.

Page Last Reviewed or Updated: 28-Mar-2017