Coordinated Issue Papers - LB&I
A major objective of the IRS Large Business and International Division's Issue Management Strategy is to identify, coordinate and resolve complex and significant industry wide issues by providing guidance to field examiners and ensuring uniform application of the law. Uniformity is achieved through the issuance of coordinated issue papers, which, following review by the Office of Chief Counsel, are issued by the Commissioner, Large Business and International Division. Although these papers are not official pronouncements on the issues, they do set forth the Service's current thinking.
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ALL INDUSTRIES (Cross All Industry Lines)
- The Applicable Recovery Period under § 168(a) for Open-Air Parking Structures - 07-31-2009
- "Basis Shifting" Tax Shelter - 12-03-2002
- Contingent Liabilities - 04-04-2003
- Cost Sharing Stock Based Compensation - 03-20-2008
- Covenants Not to Compete - Revised 02-19-1996
- Credit for Increasing Research Activities - Extraordinary Expenditures for Utilities - 05-09-2006
- Credit for Increasing Research Activities - Qualified Research Expenses - 06-18-2004
- Deduction of Contributions to IRC section 401(k) Plans Attributable to Compensation Paid After Year End Under IRC section 404(a)(6) - Revised 09-24-2004
- Distressed Asset/Debt Tax Shelters - 04-18-2007
- Distressed Asset Trust (DAT) Tax Shelters - 03-23-2010
- Dollar Value LIFO: Segment of Inventory Excluded for the Computation of the LIFO Index - 06-26-1995
- Dollar Value LIFO: Bargain Purchase Inventory - 09-09-1995
- Dollar Value LIFO: Earliest Acquisition Method - 10-23-1995
- Employment Contracts - 05-07-1992
- Exclusion of Income: Non-Corporate Entities and Contributions to Capital – 11-18-2008.
- False Claims Act Settlements with Department of Justice (DOJ) - 9-5-2008.
- Foreign Sales Corporations: Advance Payment Transactions - 05-25-2004
- Intermediary Transaction Tax Shelters - 12-19-2002
- IRC Section 461(f) Contested Liabilities - 11-17-2004
- IRC 1503(d) Mirror Legislation and the United Kingdom - 04-10-2007
- Lease Stripping Transaction - 07-21-2000
- Leveraged Oil and Gas Drilling Partnerships - 07-31-2009.
- Losses Claimed and Income to be Reported from Lease In/Lease Out Transactions - 10-17-2003
- Losses Claimed and Income to be Reported from Sale In/Lease Out (SILO) Transactions - 06-29-2005.
- Losses Reported from Inflated Basis Assets from Lease Stripping Transactions - Revised 03-15-2005
- Meal Allowances - 04-14-1994
- "Notice 2002-21" Tax Shelter - 10-15-2004
- "Notice 2002-50" Tax Shelter - Revised 05-24-2005
- "Notice 2002-65" Tax Shelter - 05-09-2005
- "Notice 2003-81" Tax Shelter - 07-26-2005 ( pdf version)
- Notional Principal Contracts - 01-06-2005
- Qualifying Wages under Section 41 in Determining the Tax Credit for Increasing Research Activities - Revised 02-16-1999
- Redemption Bogus Optional Basis Tax Shelter - 01-31-2006
- Research Credit - Internal Use Software - 08-26-1999
- S Corporation Tax Shelter - 11-08-2004
- State and Local Location Tax Incentives - 05-23-2008
- Supplemental (Beneficial) Environmental Projects (SEPs) – 7-3-2008
- Transfer or Sale of Compensatory Options or Restricted Stock to Related Persons - 10-15-2004
- Variable Prepaid Forward Contracts Incorporating Share Lending Arrangements - 02-06-2008
AEROSPACE
- Cost Overruns & Underruns - 10-31-1991
- Deductibility of Illegal Bribes, Kickbacks & Other Payments - 10-31-1991
AGRICULTURE
- Federal Income Tax Withholding on Compensation Paid to Nonresident Alien Crew Member by a Foreign Transportation Entity (also a Shipping issue) Revised - 12-03-2001
BIOTECH
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Legally mandated R&E Expenses (also a Pharmaceutical issue) - 6-18-2003
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Non Refundable Upfront Fees, Technology Access Fees, Milestone Payments, Royalties and Deferred Income under a Collaboration Agreement (also a Pharmaceutical issue) – 10-18-2007.
- Accrued Interest on Nonperforming Loans (see also Savings & Loan industry Coordinated Issue Paper) - 10-31-1991
- Gross-Up Net Loans (Renamed from Foreign Withholding Taxes) - 10-31-1991
CONSTRUCTION/REAL ESTATE
- Claim Revenue Under Long-Term Contract - Revised 07-20-2006
- Per Diem Allowances for Temporary Technical Services Employees - 01-21-1997
DATA PROCESSING
- Wages of Technical Writers and the R & E Credit - Revised 7-31-1992
FOOD
- Contributions of Food Inventory to a Charitable Organization - Revised 7-31-1992
- Investment Credit on Refrigerated Structures - 10-31-1991
FOREST PRODUCTS
- Logging Truck Roads - Depreciation and Investment Tax Credit - 10-31-1991
- Losses of Timber Following an Epidemic Attack of Southern Pine Beetles - Revised 2-12-1996
- Class Life of Floating Gaming Facilities (also a Shipping Industry Issue)- 03-12-2001
- Slot Machines, Video Lottery Terminals and Gaming Furniture, Fixtures and Equipment - 4-10-2000
INSURANCE, BLUE CROSS BLUE SHIELD/HEALTH INSURANCE
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Abandonment Losses for Intangible Assets - 05-27-2005
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Conversion of Nonprofit Organizations - 06-04-08
INSURANCE, LIFE
- Abandonment Losses for Intangible Assets - 05-27-2005
- Conversion of Nonprofit Organizations - 06-04-08
- IRC Section 807 Basis Adjustment - Change in Basis v. Correction of Error - 01-06-1997
- Loss Utilization in a Life-Nonlife Consolidated Return Separate v. Single Entity Approach - 8-09-2000
INSURANCE, PROPERTY-CASUALTY
- Margins and Other Unsubstantiated Additions to Insurance Company Reserves for Unpaid Losses and Claims - 11-18-2009
MAQUILADORA
- IRC Section 168 (g)(1)(A) - Revised 07-23-1997
- IRC Section 1504 (d) Election - 02-25-1998
MEDIA/COMMUNICATIONS
- Like-Kind Exchanges Involving Federal Communications Commission Licenses - Revised 04-03-2007
- Transition Property - 06-15-1995
MINING
- Excess Moisture - Revised 04-02-1999
- Receding Face Deduction - 10-22-2001
- Strike Costs - 05-24-1993
MOTOR VEHICLE
- Dollar-Value LIFO Definition for an Item - 10-31-1991
- Excess Parts Inventory - Revised 09-30-1998
- Remanufacturers' Inventory of Cores - 10-31-1991
- The revised coordinated issue paper on Employee Tool & Equipment Plans (Previously Service Technicians' Tool Reimbursement Plans) Revised 7/2/2008
PARTNERSHIP
PETROLEUM
- Capitalization of Delay Rentals - 09-19-1997
- Cost Depletion - Recoverable Reserves - 01-13-1997
- Leaking Underground Storage Tank Remediation Reimbursement Program – 2-5-2009.
PHARMACEUTICAL
- Legally mandated R&E Expenses (also a Biotech issue) - 6-18-2003
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Medicaid Rebates - 04-17-1997
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Non Refundable Upfront Fees, Technology Access Fees, Milestone Payments, Royalties and Deferred Income under a Collaboration Agreement (also a Biotech issue) – 10-18-2007.
RETAIL
- ACRS & ITC - Suspended Acoustical Ceilings - 10-31-1991
- Heating, Ventilating, and Air Conditioning (HVAC) Systems ACRS & ITC - 10-31-1991
- Leaking Underground Storage Tank Remediation Reimbursement Program – 2-5-2009.
- Tenant's Rent Leveling IRC Section 467 Lease Agreements - 11-06-1995
- Valuation of an Acquired Retailer's Inventory - 10-31-1991
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Accrued Interest on Nonperforming Loans (see also
Commercial Banking industry Coordinated Issue Paper) - 10-31-1991
- Supervisory Goodwill - Revised 5-11-2010 - 05-18-2010
SECURITIES & FINANCIAL SERVICE FIRMS
- Capitalization of Costs to Obtain Management Contracts - 03-25-1994
- Reverse Conversions - 10-31-1991
- Taxable Year of Inclusion of Stockbroker's Commission Income - Revised 09-13-1993
- Class Life of Floating Gaming Facilities (Also a Gaming Industry Issue) - 03-12-2001
- Federal Income Tax Withholding on Wages Paid to U.S. Crew by a Foreign Transportation Shipping Entity - 05-03-1993
- Federal Income Tax Withholding on Compensation Paid to Nonresident Alien Crew Member by a Foreign Transportation Entity (also an Air Transportation issue) - Revised 12-03-2001
- IRC Section 863(c)(2) Source of Income from Transportation Between Foreign Country Ports and United States' Deep Water Ports - 09-08-1996
TELECOMMUNICATIONS
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Universal Service Fund Reimbursements - 10-24-2003
UTILITIES
- Excess Deferred Taxes and Section 1341 - 04-24-1995
- Membership Payments made to Industry-Created Research Organizations - 07-01-1993
- United Kingdom Windfall Tax - 05-22-2002
COORDINATED ISSUES - LISTED TRANSACTIONS
Internal Revenue Manual (IRM) 4.51.2 provides that a listed transaction will be treated as a coordinated issue as of the date the listing notice is issued. A listed transaction is one that the IRS has determined to be structured for the significant purpose of tax avoidance or evasion. A memorandum from the responsible IRS Division Commissioner will be issued regarding the coordination of the issue, and a coordinated issue paper will be prepared and issued at a later date.
- Notice 2007-57 (Loss Importation Transaction) – June 20, 2007
- Notice 2008-34 (Distressed Asset Trust Transaction) - February 27, 2008
Page Last Reviewed or Updated: 2012-09-28
