The IRS Seeks Feedback on Enhanced Tax Certainty Programs for Business Taxpayers

The Internal Revenue Service (IRS) is putting out a call to business taxpayers and their advisors. The goal is to get feedback on how to bolster and broaden tax certainty and resolution mechanisms for business entities.

Rooted in the IRS Strategic Operating Plan, specifically under Initiative 2.4, the emphasis is clear: to provide taxpayers with avenues to address potential compliance concerns even before filing through an expanded suite of pre-filing and tax certainty programs.

The IRS currently boasts an array of such programs tailored to diverse taxpayers and issues. This includes the Dispute Prevention and Resolution for Large Business and International Taxpayers, the IRS Employee Plans Compliance Resolution System (EPCRS), and the Voluntary Classification Settlement Program (VCSP).

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But in its quest to offer better and more efficient services, the IRS is looking into possible improvements to these existing programs. The objective? A faster, more streamlined resolution process for taxpayer issues and a cut down on post-filing compliance activities for those taxpayers who decide to participate. Additionally, the IRS is keen on gauging the worth of novel or alternative programs, all in the interest of promoting tax clarity and issue resolution for business taxpayers, irrespective of their size.

Here’s What The IRS Wants To Know:

  1. Scope and Eligibility: The IRS is interested in understanding the scope of such a program and which issues should be included or excluded initially. There’s also a need to define eligible taxpayers’ exact population, potentially considering whether they’re publicly traded, operate under a strong tax control framework, or have audited financial statements.
  2. Existing Programs: Feedback is requested on various existing programs:
    • Compliance Assurance Process (CAP): A voluntary audit system where the IRS and taxpayers collaboratively work towards tax compliance before filing the tax return.
    • Pre-Filing Agreements (PFAs): Insight on how to optimize PFAs to ensure tax certainty.
    • Industry Issue Resolution (IIR): Suggestions to grow and refine the current program.
    • Competent Authority Assistance: Experiences where a treaty jurisdiction hasn’t accepted the IRS Form 6166, Certification of U.S. Tax Residency, are sought.
    • Voluntary Submission Program: Feedback on voluntary submissions to resolve taxpayer matters.
    • Pass-Through Entities: Thoughts on boosting tax clarity from the entity level through to the ultimate taxpayer.

To ensure this endeavor is a success, the IRS is placing a high premium on stakeholder feedback. Taxpayers and their representatives can directly voice their opinions and suggestions by emailing The deadline for submission is set for March 31, 2024.

Notably, this call for feedback is distinct from the one announced on July 27, 2023, which focused on enhancing post-filing alternative dispute resolution programs. Through such initiatives, the IRS is signaling a proactive approach in its ongoing efforts to foster a more transparent and collaborative relationship with taxpayers.

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