January 21, 2014
Impacted IRM 4.51.2
|MEMORANDUM FOR||All LB&I Employees|
|FROM:||Heather C. Maloy /s/ Heather C. Maloy
Commissioner, Large Business & International Division
|SUBJECT:||De-coordination of All LB&I Coordinated Issue Papers|
IRM 22.214.171.124 sets forth procedures for Coordinated Issue Papers, which are administrative guidance regarding technical issues that are binding on all IRS examiners. LB&I recently undertook a review of all outstanding Coordinated Issue Papers in consultation with all of the Associate offices in the Office of Chief Counsel and with the Office of Appeals.
Effective with the issuance of this LB&I Directive, all current Coordinated Issue Papers are de-coordinated. To the extent that any Coordinated Issue Paper included guidance or tools relevant to addressing an issue or transaction, such guidance or tools will be made available through the IPG and IPN community websites, which may be consulted by examiners with questions about how to address a technical issue. Certain issues or procedures currently addressed in a CIP may be addressed in future LB&I directives or other guidance. The de-coordination of any coordinated issue has no effect on whether the issue will continue to be pursued by LB&I in a taxpayer examination or on the Service’s views regarding any transaction, including listed transactions. The IRM will be updated to reflect the changes announced in this directive.
The IPGs and IPNs for these respective issues will provide guidance and support to examiners on any of the issues being de-coordinated by this directive.
This LB&I Directive is not an official pronouncement of law and cannot be used, cited or relied upon as such.
Cc: Division Counsel, LB&I