Recently, the IRS’s Large Business and International Division issued guidance for business taxpayers which laid out 13 “campaigns” it plans to target in 2017. While this lists targets last businesses, it will likely trickle down to small and mid-sized businesses as well.
The 13 “campaigns” or areas they plan to target are:
- examinations of the energy credit described in Internal Revenue Code 48C;
- declines and withdrawals from the offshore voluntary disclosure program;
- related-party transactions;
- repatriation of income from overseas locations;
- foreign companies doing business in the United States that are not filing appropriately;
- transfer pricing associated with inbound distribution of goods from related parties outside the United States;
- deferred variable annuity reserves and life insurance reserves;
- basket transactions that seek to treat ordinary income and short-term capital gain as long-term;
- micro-captive insurance contracts;
- the completed contract method of accounting applied by land developers;
- application of the domestic production activities deduction to certain entertainment products;
- risks associated with larger, more complex pass-through partnerships; and
- losses claimed in excess of basis in S corporations.The IRS did not provide detailed information on how they plan to address these areas. For more information, please contact us.