A taxpayer interested in applying for the 2024 CAP year that meets the eligibility and suitability criteria must complete and submit the required CAP application during the application period that starts on September 6, 2023, and ends on October 31, 2023. See CAP Eligibility and Suitability Criteria. The CAP application contains the following forms: Form 14234 CAP Application; Form 14234-A CAP Research Credit Questionnaire (CRCQ); Form 14234-B Material Intercompany Transactions Template (MITT); Form 14234-C Taxpayer Initial Issues List (TIIL); Form 14234-D Tax Control Framework Questionnaire (TCFQ) and Form 14234-E CAP Cross Border Activities Questionnaire (CBAQ) DRAFT If you are a returning applicant, see MITT Submission Process for Returning Applicants, or if you are a new applicant, see MITT Submission Process for New Applicants. See the instructions in the CBAQ for new and returning applicant instructions. The application is available on the CAP Program webpage and should be submitted by one of the following methods: If the taxpayer is a returning applicant, submit the application to the Account Coordinator or Case Manager assigned to the case. If the taxpayer is a new applicant, email the application to the CAP Program mailbox. Enter "CAP Application" and the tax year in the subject line. If a taxpayer meets the eligibility and suitability criteria, the application will be forwarded to the LB&I Compliance Practice Area Director with jurisdiction over the taxpayer for an evaluation of the application. If a taxpayer’s application is approved by the IRS, the taxpayer will be notified, in writing, by the Territory Manager assigned to the taxpayer, that it was accepted into the CAP Program and selected for one of the three phases of the Program. The IRS, in its sole discretion, may decline to approve a taxpayer’s application whenever warranted by the facts and circumstances of the application or in the interest of sound tax administration. If a taxpayer’s application is not approved by the IRS, the taxpayer will be notified, in writing, by the Territory Manager assigned to the taxpayer, that it was not accepted into the CAP Program and the reason or reasons why it was not accepted into the Program. A taxpayer accepted for CAP will be provided a copy of the CAP Memorandum of Understanding (MOU) and must sign the MOU and return to the Account Coordinator by the requested date to secure participation in the Program. Adherence to the processes and procedures established by the CAP MOU is an integral part of identifying, developing, and resolving issues and assuring the IRS of the accuracy of the return. Failure to comply with the terms of the MOU may result in the removal of the taxpayer from the CAP Program.
