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Compliance Assurance Process (CAP) application and selection process

 

Application period

Taxpayers that meet the eligibility and suitability criteria may apply for the 2027 Compliance Assurance Process (CAP) year. Applications must be submitted from Sept. 1 through Oct. 30, 2026.

For eligibility and suitability requirements, see CAP eligibility and suitability criteria.

Required application forms

The CAP application package includes the following forms: 

DocumentRequired for new applicantsRequired for returning applicants
Form 14234, Compliance Assurance Process (CAP) Application PDF
Form 14234-A, Compliance Assurance Process (CAP) Research Credit Questionnaire (CRCQ) PDF
Form 14234-B, Material Intercompany Transactions Template (MITT) PDF 
Form 14234-C, Taxpayer Initial Issues List PDF
Form 14234-D, Tax Control Framework Questionnaire PDF 
Form 14234-E, Compliance Assurance Process (CAP) Cross Border Activities Questionnaire (CBAQ) PDF 

New applicants should refer to: 

How to apply

The application is available above and on the Compliance Assurance Process program webpage. 

Returning applicants:

  • Submit the application to the account coordinator or case manager assigned to the case.

New applicants:

  • Email the application to the CAP program mailbox.
  • Enter "CAP Application" and the tax year in the subject line.

IRS review and selection process

The appropriate Large Business & International (LB&I) division compliance practice area director will evaluate applications that meet the eligibility and suitability criteria.

IRS decision 

If the IRS approves an application, the taxpayer will receive written notification from the assigned territory manager confirming acceptance into the CAP program and identifying the applicable CAP phase.

If the IRS does not approve an application, the taxpayer will receive written notification from the assigned territory manager explaining the reason for non-acceptance.

Participation requirements 

Taxpayers accepted into CAP will receive a CAP Memorandum of Understanding (MOU). To secure participation in the program, the taxpayer must sign and return the MOU to the account coordinator by the requested date.

Adherence to the CAP MOU is an integral part of identifying, developing, and resolving issues and providing assurance regarding the accuracy of the return. Failure to comply with the terms of the MOU may result in removal from the CAP program.

Accepted applicants should refer to: