IRS announces changes to bridge phase of Compliance Assurance Process (CAP) program

IRS made significant changes to CAP program to improve its operation and promote best use of limited government resources

IRS announces changes to bridge phase of Compliance Assurance Process (CAP) program

The IRS today announced changes to the bridge phase of the Compliance Assurance Process (CAP) program.

According to today’s IRS release—IR-2023-25 (February 13, 2023)—the IRS made significant changes to the CAP program in 2019 to improve its operation and promote the best use of limited government resources. One outcome of this change was the development of the bridge phase in CAP, which is reserved for taxpayers whose risk of noncompliance does not support the continued use of IRS compliance resources.  

During the bridge phase, the IRS will not accept any disclosures, conduct any reviews or provide any assurances. In the three years since its inception, the IRS has received consistent feedback from taxpayers that participation in the bridge phase deprives them of the most important aspect of CAP—the review by the IRS. 

Due to this feedback, the IRS has developed a new pilot phase called “bridge plus.”

  • Taxpayers will be required to provide book-to-tax reconciliations, credit utilization and other supporting documentation shortly after their audited financial statement is finalized. An IRS team will risk-assess the documents to determine if the taxpayer is suitable for the bridge plus phase. 
  • Taxpayers accepted into this new phase will be required to submit a draft return 30 days before filing. The IRS team will review the return for consistency with the taxpayer’s prior submission. If the draft return is consistent, the taxpayer will be instructed to file a return. If the filed return is consistent with prior submissions, the taxpayer will be issued a full acceptance letter. 
  • The pilot will be offered only to CAP participants that were in the bridge phase for 2022 and have been recommended to participate in bridge again in 2023. Acceptance into the program will be based on input from multiple IRS Large Business & International practice areas as well as the low-risk determination. The IRS will notify CAP taxpayers if they are eligible to participate in the pilot.

 

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 3712, 1801 K Street NW, Washington, DC 20006.