Tax Information For Corporations

Abusive Tax Shelters and Transactions
The Internal Revenue Service has a comprehensive strategy in place to combat abusive tax shelters and transactions. This strategy includes guidance on abusive transactions, regulations governing tax shelters, a hotline for taxpayers to use to report abusive technical transactions, and enforcement activity against abusive tax shelter promoters and investors.

Additional Guidance on IRC Section 168(k)(4) Election to Accelerate Research Credits
A taxpayer with a taxable year end of June 30, is allowed the option provided by section 3.02(1)(a)(i)(I) and (II) of Rev. Proc. 2009-16 if such taxpayer files its original federal income tax return for such taxable year on or before March 11, 2009, consistent with the option available to a taxpayer who files its original federal income tax return after March 11, 2009.

Alternative Motor Vehicle Credit
The Alternative Fuel Motor Vehicle Credit was enacted by the Energy Policy Act of 2005 and includes separate credits for four distinct categories of vehicles: Hybrid vehicles, Fuel Cell vehicles, Qualified Alternative Fuel Motor vehicles (QAFMV) and Advanced Lean Burn Technology vehicles. The amount of the potential credit varies by type of vehicle and which of the four credits applies.

Appeals
The Appeals Office resolves tax controversies, without litigation, on a basis that is fair and impartial to both the Government and the taxpayer.

Application of Posted 1065 FAQ Answers to Similar Form 1120 Questions
Posted 1065 FAQ answers regarding ownership reporting for Form 1065 Schedule B questions 3 and 4 may be applied to similar issues in reporting ownership for Form 1120 Schedule K questions 4 and 5. Both sets of questions require a limited application of section 267(c) attribution rules to determine total ownership percentages, direct or indirect.

Corporate Executive Compliance
The Internal Revenue Service is taking steps to improve tax compliance by corporations and their executive employees. One area of emphasis is executive compensation, for which audit technique guides have been developed for use by agents in examining tax returns filed by corporations and executives.

e-file for Large Business and International (LB&I)
Certain large business and International (LB&I) corporations are required to electronically file their Forms 1120 and 1120S. Other corporations may do so voluntarily. This site provides e-file information for corporations that prepare and transmit their own electronic corporate income tax returns and those that use the services of third party tax professionals.

FASB Interpretation No. 48, "Accounting for Uncertainty in Income Taxes"
FIN 48 is intended to eliminate inconsistency in accounting for uncertain tax positions in financial statements certified in accordance with U.S. GAAP and mandates new rules for recognition, de-recognition, measurement, and disclosure of tax positions.

Fast Track Settlement
The LB&I / Appeals Fast Track Settlement program is a joint effort between the Large Business and International (LB&I) Division and Appeals to use the mediation skills and delegated settlement authority of Appeals to resolve issues while still under LB&I jurisdiction.

Filing Requirements for Filing Status Change (revised 11-15-11)
Guidance for taxpayers requesting to change their filing status from a C Corporation (filing Form 1120) to an S Corporation (filing Form 1120S).

Foreign Account Tax Compliance Act (FATCA)
FATCA will increase information reporting by foreign financial institutions, non-financial foreign entities, and certain U.S. persons holding financial assets outside the United States.

Forms 5471 - Automatic Assessment of Penalties under IRC Section 6038(b)(1)
Beginning January 1, 2009, the Internal Revenue Service Center will automatically assert appropriate penalties on late filed Forms 1120 with Forms 5471 attached. Taxpayers are encouraged to submit delinquent Forms 5471 prior to January 1, 2009.

Form 8806 - Information Return for Acquisition of Control or Substantial Change in Capital Structure
Pursuant to the provisions of Temporary Regulation § 1.6043-4T(a), requiring reporting of certain acquisitions of control and substantial changes in capital structure, corporations can consent to the publication by the IRS of the information from their Form 8806.

Income from Abroad is Taxable
There have been recent reports about the interest of the Internal Revenue Service (IRS) in taxpayers with bank accounts in Liechtenstein. The IRS' interest, however, extends beyond bank accounts in Liechtenstein to financial accounts anywhere in the world. The IRS reminds you to report your worldwide income on your U.S. tax return and lists the possible consequences of hiding income overseas.

Index of Large Business and International (LB&I) Division Industry Overviews
The LB&I Industry Overview Series, designed to provide LB&I employees greater awareness of various industries, contain information on industry background, trends, and terms, accounting principles, information systems, industry operating procedures, government regulatory requirements, significant law and important issues and industry resources.

Industry Issue Resolution Program
The Industry Issue Resolution (IIR) Program resolves frequently disputed or burdensome tax issues. IRS solicits suggestions for issues for the program from taxpayers, representatives and associations.

The International Tax Gap
Find resources on this page pertaining to the international tax gap — the difference between the amount of tax that taxpayers should pay and the amount that is paid voluntarily and on time. The tax gap can also be thought of as the sum of non-compliance with the tax law.

Issue Tiering - LB&I
LB&I's Issue Tiering issue management strategy promotes consistency in issue resolution, improves currency, increases coverage of non-compliant taxpayers, and provides greater oversight and accountability for important issues.

Limited Issue Focused Examination (LIFE)
The IRS Large Business and International (LB&I) Division is implementing a new streamlined examination process.

LB&I Technical Resources and Guidance
Coordinated issue papers, Industry Director guidance, audit technique guides and other documents provide technical information and guidance on complex tax law and administrative issues affecting the LB&I division and LB&I taxpayers.

New Identification Number Implemented for Certain Foreign Information Returns
New Identification Number Implemented for Certain Foreign Information Returns

Pre-Filing Agreement Program
The Pre-Filing Agreement Program is expected to reduce taxpayer burden and make more effective use of IRS resources by resolving or eliminating tax controversy earlier in the examination process.

Report of Foreign Bank and Financial Accounts (FBAR)
If you own a foreign bank account, brokerage account, mutual fund, unit trust, or other financial account, then you may be required to report the account yearly to the Internal Revenue Service.

S Corporations
An eligible domestic corporation can avoid double taxation (once to the shareholders and again to the corporation) by electing to be treated as an S corporation.

Schedule M-3 for Large Business & International (LB&I)
Schedule M-3 is used by certain corporations and partnerships to reconcile financial accounting net income and taxable income. Affected corporations and partnerships are those with assets of $10 million or more that file Form 1120, 1120-PC, 1120-L, 1120S, or 1065. Certain other partnerships filing Form 1065 are also required to use the Schedule M-3.

2008 Changes to Form 1065 - Frequently Asked Questions
Form 1065 has a number of changes for 2008. For example, Schedule B and Schedule K-1 require reporting of ownership percentages. The FAQ page on Form 1065 changes offers helpful examples.

U.S./Germany Tax Treaty Modified to Include Mandatory Arbitration in Certain Circumstances
A new Protocol modifying certain provisions of the income tax treaty between the U.S. and Germany came into force on Dec. 28, 2007. It modifies Article 25 Mutual Agreement Procedure (MAP) to provide for mandatory arbitration of certain cases in the MAP. This announcement provides interim guidance for the “commencement date” for MAP case arbitration until a formal mutual agreement is published.

Uncertain Tax Positions - Schedule UTP
IRS finalized Schedule UTP & instructions for reporting uncertain tax positions by certain corporations.

Understanding the Large Business and International (LB&I) Division Examination Process
This comprehensive guide gives detailed information about the entire examination process for large businesses and international, from the multiple steps of the pre-audit planning process to the examination of books and records through the closing and Appeal processes.