Cross Border Activities Questionnaire (CBAQ) submission process for accepted Compliance Assurance Process (CAP) taxpayers

Accepted Compliance Assurance Process (CAP) taxpayers must submit the Cross Border Activities Questionnaire (CBAQ) according to the schedule below. Submission requirements differ depending on the taxpayer’s phase in the CAP program. Taxpayers in CAP and Compliance Maintenance (CM) phases submit initial, interim (if necessary), and final CBAQs. Taxpayers in the Bridge Plus phase submit only initial CBAQs.

Initial CBAQ

CAP and CM phases

A taxpayer in the CAP or CM phase must submit the initial CBAQ within 90 days after the end of the prior tax year using projections for the current CAP year. If the initial CBAQ necessitates the use of tax provision estimates, note this on the form. The initial CBAQ is used by the CBA Risk team to begin the risk assessment process for the current CAP year.

For example, a calendar year end taxpayer participating in CAP for the 2027 tax year must submit the initial CBAQ by March 31, 2027. The CBA Risk team uses this initial CBAQ to begin the risk assessment for the 2027 CAP year.

Bridge Plus phase

A taxpayer in the Bridge Plus phase must submit the initial CBAQ as part of its Bridge Plus documentation package, which is due within four months after the end of the tax year. The initial CBAQ supports the Bridge Plus risk assessment conducted after the close of the tax year.

For example, a calendar year end taxpayer in the Bridge Plus phase for the 2027 tax year must submit the initial CBAQ with its Bridge Plus documentation package by April 30, 2028.

Interim CBAQ (if necessary)

CAP and CM phases only

A taxpayer in the CAP or CM phase must submit an interim CBAQ within 30 days after completing any material transaction or activity identified in the CBAQ. The interim CBAQ should report only updates to the applicable transactions. If any CAP year question on the initial CBAQ was answered “to be determined,” the taxpayer must update that response within 30 days after obtaining the necessary information.

For example, if a material new transaction occurs on June 9, 2027, an interim CBAQ reporting this transaction must be submitted by July 9, 2027. The CBA Risk team uses this CBAQ to update its risk assessment for the 2027 tax year.

Final CBAQ

CAP and CM phases only

A taxpayer in the CAP or CM phase must submit a final CBAQ when the tax return for the CAP year is filed. The final CBAQ facilitates the team’s post-filing review.

For example, on Oct. 16, 2028, a calendar year end taxpayer files Form 1120 for the 2027 tax year. The taxpayer submits the final CBAQ on Oct. 16, 2028. The final CBAQ is used to complete the post-filing review of the 2027 CAP year.