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LB&I activities that are temporarily suspended, continued (COVID-19)

LB&I division activities

The Commissioner of the IRS Large Business and International (LB&I) Division issued a memorandum addressing which LB&I compliance activities would be postponed and which would be allowed through July 15, 2020, as a result of the coronavirus (COVID-19) pandemic.


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Read the memorandum: LB&I-04-0420-0009 [PDF 34 KB]

LB&I activity postponed through July 15, 2020

  • LB&I will not start an examination of any new return unless it falls within a continuing activity, as defined in the memorandum.
  • LB&I managers have discretion with respect to examinations of prior, subsequent, and related returns associated with an existing examination.

Approval of continuing activities by LB&I

  • Compliance assurance process, large corporate compliance, FATCA, qualified intermediary programs and current open examinations—to proceed as usual, but without in-person contact.
  • New examinations arising from Voluntary Disclosure Practice cases, claims, and other pre-refund verification programs—to proceed as usual, but without in-person contact.
  • Work is to continue on the following cases: Syndicated conservation easements campaign cases, micro-captive insurance campaign cases, IRC section 965 campaign cases, and any future campaign-related cases involving the “Tax Cuts and Jobs Act” (TCJA), but without in-person contact. Existing and any new campaigns will be assessed for purposes of categorizing as postponed or allowed with clear communications to follow on which are allowed.
  • Workload reviews of existing inventory will continue.
  • Examiners can charge time to new cases (e.g., audit planning) when taxpayer contact will not be made until after the emergency declaration is lifted.
  • Prior time limits on classification activities are suspended.
  • Other consensual work initiated by taxpayers to proceed as usual, but without in-person contact, for example, pre-filing agreements, refund claims.

The memorandum concludes that while guidelines cannot be anticipated or provided for every possible situation, LB&I employees are directed to be sensitive to the individual circumstances of taxpayers and provide them with the appropriate tax administrative actions commensurate with the taxpayer’s situation. 

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