Compliance Assurance Process (CAP)

The Compliance Assurance Process (CAP) helps large corporate taxpayers improve federal tax compliance by working with the IRS to identify and resolve issues before tax returns are filed. 

Through CAP, taxpayers and the IRS can:

•  Resolve issues in real time 
•  Improve tax compliance and certainty
•  Increase return accuracy
• Reduce post-filing examination activity

For questions or comments, contact the CAP program mailbox.

Apply for CAP

2027 application period

• Applications accepted: Sept. 1 – Oct. 30, 2026
• Applicant notifications of acceptance: February 2027

Application resources

• Highlights and updates for the CAP 2027 application period
• CAP application and selection process
• CAP eligibility and suitability criteria
• CAP frequently asked questions

Current CAP documents

• 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
• 2027 CAP Memorandum of Understanding (MOU)

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 Additional resources

Form 14234-F, Post-Filing Representation by Taxpayer PDF

MITT and APA frequently asked questions

CAP Internal Revenue Manual (IRM)

 Prior year resources

Bridge phase frequently asked questions

2026 CAP Memorandum of Understanding (MOU) PDF

2025 CAP Memorandum of Understanding (MOU) PDF

2024 CAP Memorandum of Understanding (MOU) PDF

CAP history

• The IRS Large Business and International (LB&I) division developed the CAP program.
• CAP  began as a pilot program in 2005 and became permanent in 2011.
•  The program was recalibrated  beginning with the 2019 CAP year.
•  In 2019,  the IRS announced that eligible U.S. publicly traded corporate taxpayers  could apply for the 2020 CAP year.
•  In 2022,  the IRS reinstated the one-open-return eligibility criteria for returning applicants.
•  In 2024,  the IRS made the Bridge Plus phase  permanent  for the 2025 CAP year.
•  In 2025,  the IRS expanded eligibility to U.S. privately held C corporations .