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

2020

Date Title
03-10-20 LB&I Directive on the Centralized Risking of Research Issues under IRC §§ 41 & 174

2019

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)
08-06-19 LB&I and SBSE Joint Directive on Creditability of French Social Taxes
07-31-19 Withdrawal of Directive LB&I-04-0118-005, Instructions for Examiners on Transfer Pricing Issue Selection – Cost-Sharing Arrangement  Stock Based Compensation, dated January 12, 2018
05-21-19 Withdrawal of Directive LB&I-04-0118-004, Instructions for Examiners on Transfer Pricing Issue Selection-Reasonably Anticipated Benefits in Cost Sharing Arrangements

2018

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)
01-12-18 Interim Instructions on Issuance of Mandatory Transfer Pricing Information Document Request (IDR) in LB&I Examinations
01-12-18 Instructions for Examiners on Transfer Pricing Issue Examination Scope - Appropriate Application of IRC §6662(e) Penalties
01-12-18 Instructions for LB&I on Transfer Pricing Issue Selection- Reasonably Anticipated Benefits in Cost Sharing Arrangements 
01-12-18 Instructions for LB&I on Transfer Pricing Selection and Scope of Analysis - Best Method Selection

 2017

Date Title
10-19-17 Large Business & International Directive for Determining Units of Property and Major Components in the Mining Industry
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
09-11-17 Large Business & International Directive for Determining Units of Property and Major Components in the Mining Industry

2016

07-06-15 LB&I Directive for Determining When "Substantially All" of a Major Component (as Defined in Revenue Procedure 2013-24) has been Replaced under I.R.C. Section 263(a)
04-16-15 LB&I Directive on the Examination of Taxpayers Using the Safe Harbor Methods of Accounting for Cable Network Assets
03-16-15 LB&I Directive on the I.R.C. § 199 Definition of "Manufactured, Produced, Grown, or Extracted"

2015

Date Title
07-06-15 LB&I Directive for Determining When "Substantially All" of a Major Component (as Defined in Revenue Procedure 2013-24) has been Replaced under I.R.C. Section 263(a)
04-16-15 LB&I Directive on the Examination of Taxpayers Using the Safe Harbor Methods of Accounting for Cable Network Assets
03-16-15 LB&I Directive on the I.R.C. § 199 Definition of "Manufactured, Produced, Grown, or Extracted"

2014

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
09-03-14 Large Business & International Directive Extending Transition Rules and the Scope Limitation Waiver for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property-LB&I Directive #3
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

2013

Date Title
10-29-13 Updated Guidance for Examiners on I.R.C. § 199 Benefits and Burdens of Ownership Analysis in Contract Manufacturing Arrangements
06-10-13 Large Business & International Directive for Taxpayers Changing to the Method of Accounting Provided in Rev. Proc. 2013-24 for Steam or Electric Generation Property
05-02-13 Extension of Transition Rules for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property - LB&I Directive #2
03-22-13 UPDATED LB&I DIRECTIVE for Taxpayers Who Adopted a Method of Accounting Relating to the Conversion of Capitalized Assets to Repair Expense under I.R.C. Section 263(a)

2012

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
01-23-12 Large Business and International Directive Wireless Telecommunication Assets
01-23-12 Large Business & International Directive Telecommunication Carriers Change in Method of Accounting Relating to Conversion of Capitalized Assets to Repair Expense Under I.R.C. Section 263(a)

2011

Date Title
11-25-11 Large Business & International Directive Transition Rules for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property
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

2010

Date Title
05-13-10 Use of Delegation Order (DO) 4-25 on Appeals Settlement Position (ASP) for the I.R.C. § 41 Research Credit – Intra-Group Receipts from Foreign Affiliates (IRM 4.46.5.6)

2009

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

2006

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

2005

Date Title
11-28-05 Industry Director Directive on the Planning and Examination of Cost Segregation Issues in the Biotech/Pharmaceutical Industry
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

2004

Date Title
12-27-04 Planning and Examination of Cost Segregation Issues in the Restaurant Industry
12-16-04 Planning and Examination of Cost Segregation Issues in the Retail Industry
10-12-04 IRC Sec. 907 Evaluating Taxpayer Methods of Determining Foreign Oil and Gas Extraction Income (FOGEI) and Foreign Oil Related Income (FORI)
07-31-04 Cost Depletion - Determination of Recoverable Reserves
04-30-04

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

04-16-04

Timber Casualty Losses

2003

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

2002

Date Title
04-08-02 MACRS Asset Categories for Refinery Assets
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

2001

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