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Issue Number:? ??IR-2023-171Inside This IssueIRS requests comments on expanding tax certainty and issue resolution programs for business taxpayers WASHINGTON ? The Internal Revenue Service is requesting comments from taxpayers and advisors about improving and expanding tax certainty and issue resolution options for business taxpayers. The IRS Strategic Operating Plan, under Initiative 2.4, highlights a commitment to enabling taxpayers to resolve potential compliance issues up front, through expanded pre-filing and tax certainty programs. To achieve this, the IRS is evaluating current tax certainty programs and tools to determine potential enhancements that would enable faster resolution of taxpayer issues and a reduction in post-filing compliance activities for participating taxpayers. The IRS is also evaluating the value of new or alternative programs to advance tax certainty and issue resolution for business taxpayers of all sizes. The IRS presently has a number of tax certainty and issue resolution programs applicable for a variety of taxpayers and issues, such as, Dispute Prevention and Resolution for Large Business and International Taxpayers, the IRS Employee Plans Compliance Resolution System (EPCRS) and the Voluntary Classification Settlement Program (VCSP). Request for Comments Specific comments are requested on:
In addition to the general request for comments above, we invite feedback on the programs and suggestions identified below: ? Compliance Assurance Process (CAP) Comments are invited on whether IRS should consider modifications to the eligibility requirements or other program features, including, whether eligibility requirements should be modified to include any taxpayer that prepares an annual financial statement that is audited by a third party, or whether there?s a value for partnership CAP in light of the IRS? plans for increased coverage of partnership structures. ? Pre-Filing Agreements (PFAs) ? Industry Issue Resolution (IIR) ? Competent Authority Assistance for U.S. Residency Determinations Comments are invited about instances where a treaty jurisdiction has not accepted a Form 6166, Certification of U.S. Tax Residency, for a U.S. treaty resident to claim benefits. Please include the name of the country, the stated reason the jurisdiction would not accept Form 6166, the country-specific requirements, and/or whether certain clarifications on the residency status of a U.S. treaty resident would be helpful. These comments will help inform whether and how the U.S. Competent Authority (USCA) may be able to help in such instances, for example, by providing a supplemental letter for U.S. taxpayers who have received an IRS Form 6166 but are still unable to claim treaty benefits in foreign jurisdictions. ? Voluntary Submission Program Taxpayers should typically file amended or delinquent returns, or, where available, request relief pursuant to existing programs or income tax return instructions. In some cases, those may not be the best methods for resolving taxpayer errors, omissions and other corrections, and a voluntary submission by the taxpayer may be more appropriate. ? Pass-Through Entities It should be noted that 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. ? Thank you for subscribing to the IRS Newswire, an IRS e-mail service. If you know someone who might want to subscribe to this mailing list, please forward this message to them so they can subscribe. This message was distributed automatically from the mailing list IRS Newswire. Please Do Not Reply To This Message. |
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