Large Business & International 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


Date Title
10-10-19 LB&I and SB/SE Joint Directive on the Work Opportunity Tax Credit per Internal Revenue Code Section 51 (IRC § 51)


Date Title
11-29-18 LB&I Directive on Amended Return/Claim for Refund Relating to Internal Revenue Code Section 199 (IRC § 199)
08-27-18 LB&I Directive on Timeshare Issue
08-24-18 IRC Section 807: LB&I Directive Related to Principle Based Reserves for Variable Annuity Contracts (AG 43/VM-21) and Life Insurance Contracts VM-20)


Date Title
09-11-17 Activities under I.R.C §41 for Taxpayers that Expense Research and Development Costs on their Financial Statements pursuant to ASC 730


Date Title
03-16-15 LB&I Directive on the I.R.C. § 199 Definition of "Manufactured, Produced, Grown, or Extracted"


Date Title
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
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


Date Title
10-29-13 Updated Guidance for Examiners on I.R.C. § 199 Benefits and Burdens of Ownership Analysis in Contract Manufacturing Arrangements


Date Title
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
07-30-12 I.R.C. §166: LB&I Directive Related to Partial Worthlessness Deduction for Eligible Securities Reported by Insurance Companies


Date Title
11-01-11 UTP Guidance and Procedures for the Field
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
02-04-11 Industry Directive to Withdraw Prior IDD on FSC IRC § 921-927 Bundle of Rights in Software Issue


Date Title
11-03-09 Field Directive on the Use of Estimates from Probability SamplesPDF


Date Title
07-31-06 Industry Director Directive on Deductibility of Casino Complimentary Goods and Services
03-16-06 Industry Director Directive on Treatment of Semiconductor Assembly and Test Activities as Manufacturing


Date Title
08-26-05 Industry Director Directive Amended Returns/Refund Claims Containing Invalid IRC § 280(C)(3) Elections
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


Date Title
10-12-04 IRC Sec. 907 Evaluating Taxpayer Methods of Determining Foreign Oil and Gas Extraction Income (FOGEI) and Foreign Oil Related Income (FORI)

Planning and Examination of Research Credit Issues in a Branded Pharmaceutical Company


Timber Casualty Losses


Date Title
11-14-03 Foreign Sales Corporations (FSC) IRC § 921-927 Bundle of Rights in Software Issue
10-17-03 Examination of Legally Mandated Research and Experimentation Expenses in the Biotech and Pharmaceutical Industries
03-24-03 Planning and Examination of Construction "Tenant" Allowances for Leases Greater Than 15 Years


Date Title
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


Date Title
12-12-01 Conformity Election for Bank Bad Debts