IRS request for comments on expanding tax certainty and issue resolution programs for business taxpayers

IRS welcomes comments on opportunities to expand and enhance tax certainty and issue resolution across the entire business taxpayer population

IRS request for comments on expanding tax certainty and issue resolution programs

Article Posted date 15 September 2023

The IRS today issued a release requesting comments from taxpayers and advisors about improving and expanding tax certainty and issue resolution options for business taxpayers.

According to the IRS release—IR-2023-171 (September 15, 2023)—the IRS welcomes comments on opportunities to expand and enhance tax certainty and issue resolution across the entire business taxpayer population, whether by enhancing existing programs and tools or developing new ones. Comments can be sent to LBI.SOP.Initiative.Feedback@irs.gov by March 31, 2024, specifically concerning:

  • The scope of the program, with specific examples of issues that would be appropriate for coverage under the program and issues that could be carved out of scope initially (e.g., limited to domestic issues) or generally (e.g., "comfort" requests)
  • The parameters for defining the population of eligible taxpayers (e.g., publicly traded, audited financial statements, materiality, taxpayers operating under a robust tax control framework) or ineligible taxpayers (e.g., engaging in listed transactions or other abusive transactions, taking positions inconsistent with a Treasury regulation)
  • Timeframe for application to the program (e.g., cut-off date of no more than X months after return filing)
  • Resolution options other than traditional examination
  • Expectations with respect to taxpayers not accepted into the program (e.g., filing an amended return)
  • Potential for initiating a program as a limited scope pilot
  • Recommended guardrails to ensure program's scope would be consistent with applicable law and does not undermine timely information reporting to the fullest extent feasible, as well as the timely and accurate filing of returns

In addition to the general request for comments above, the IRS invites feedback on:

This invitation for feedback is separate from the invitation announced on July 27, 2023, to submit feedback to help IRS improve post filing alternative dispute resolution programs. Read TaxNewsFlash

 

Download pdf (1.2 MB)

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.