Share with your friends

IRS adds new compliance campaigns on fuel credit, research issues (LB&I division)

IRS adds new compliance campaigns

The IRS Large Business & International (LB&I) division continues to expand its list of compliance campaigns today by adding two new campaigns—bringing the current total to 53 compliance campaigns.


Related content

As included on the IRS website (last updated February 27, 2020), the new campaigns concern:

  • Section 6426 fuel credit. The compliance campaign is briefly described by the IRS as follows: 

LB&I is initiating a campaign for taxpayers who received fuel mixture credits under ... section 6426, but did not treat the credits as a reduction in their excise tax liability under section 4081. See Sunoco Inc. v. United States, 908 F.3d 710 (Fed. Cir. 2018), cert. denied, Sup. Ct. Dkt. No. 18-1474 (2019). The goal of this campaign is to use issue-based examinations to bring taxpayers who maintain that the credits are merely refundable credits, which do not affect the deduction for any excise tax liability, into compliance.

  • Research issues: The compliance campaign is briefly described by the IRS as follows: 

The research issues campaign will address research credit and research and experimental expenditures issues. Issues involving the research credit and research and experimental expenditures under sections 41 and 174 are some of the most prevalent tax issues within LB&I, utilizing significant examination and taxpayer resources. The campaign will employ various treatment streams including issue-based examinations, form updates, and requests for guidance. Other treatment streams will be considered as the campaign progresses. The campaign objective is to promote voluntary compliance, focus resources on the highest risk research issues and increase consistency of examinations.

A separate release on the IRS website (dated February 27, 2020) reflects that the following six compliance campaigns have been “retired” as having been concluded:

  • Deferral of cancellation of indebtedness income campaign
  • Deferred variable annuity reserves and life insurance reserves IIR campaign
  • Section 48C – Energy credits campaign
  • Section 965 – Taxpayer awareness campaign
  • Land developers - Completed contract method (CCM) campaign
  • TEFRA linkage plan strategy campaign

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in 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 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal