The restructuring follows the IRS's announcement in August that, as of October 1, LMSB
would be reconfigured and renamed the Large Business & International (LB&I) Division, with a greater emphasis on international tax matters.
In the third LMSB
-04-0209-004), issued on March 4, 2009, the industry director took up the issue of how prior-period expenses might result in the creation of DPGR in future years, even though the expenses may have resulted from activities that took place prior to the effective date of section 199.
The strategic initiatives identified by the LMSB
Division for 2007 also identified principal compliance objectives a private company can use to avoid an IRS audit.
Four key differences between the LMSB
and SB/SE programs are as follows:
division relies heavily on electronic data to differentiate compliant and non-compliant corporate returns.
The Commissioner explained that the National Office appreciates that uncertain tax positions should not automatically be challenged and assured TEI that LMSB
will emphasize this during its training program.
As noted, the elevation of the repairs method change to Tier I status has been widely anticipated by tax professionals, and the new directives reiterate the key points outlined in the previously released LMSB
emerging issue memorandum (LMSB
The existing pilot is limited to taxpayers in the LMSB
Division of the IRS.
Commissioner Maloy welcomed TEI President Neil D.
taxpayers currently under IRS examination on another matter should contact the IRS team manager supervising the audit to initiate the process and work with the exam team to prepare the formal PFA request.
Maloy said that one LMSB
goal for the year is to refine its process for issue management.
However, the IDD lists the following MSC allocation methods as examples of those that the LMSB
considers relatively more significant for compliance priorities: