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Mark Allison Talks to Tax Notes on IRS Corporate Audit Campaigns

October 25, 2019, Tax Notes

The IRS’s multiyear experiment with targeted Large Business and International Division compliance campaigns needs significant retooling, a Treasury watchdog says.

. . .

But Mark Allison of Caplin & Drysdale said, “I think TIGTA’s assessment may not reflect the reality and difficulty of identifying issues that are appropriate for a campaign.”

Issues appropriate for LB&I’s campaign treatment are often revealed only after extensive evaluation of taxpayer reporting positions and selective audits, which provide the basis for a wider range of examinations and disclosures to determine which taxpayer positions are compliant or appropriate, Allison said.

“A campaign should not necessarily presuppose that an issue requires a determination of noncompliance, only that the issue requires further assessment because it poses a risk of noncompliance,” Allison said.

For the full article, please visit Tax Notes’ website (subscription required).


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