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.


Related content

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. 

The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained 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