LB&I directive - Coordinated issue papers are de-coordinated 

January 21: The IRS Large Business and International (LB&I) division today posted an LB&I directive providing that, effective today, all current coordinated issue papers (CIPs) are de-coordinated. LB&I-04-0114-002 (January 21, 2014)

Background

CIPs are administrative guidance regarding technical issues that were binding on IRS examiners. A major objective of LB&I’s Issue Management Strategy is to identify, coordinate, and resolve significant and complex industry-wide issues by providing guidance to examiners and maintaining uniform application of the law.


CIPs have been one of the tools used by LB&I in pursuit of this objective. Although CIPs are not official pronouncements, they set forth the IRS’s current thinking on issues.

Today’s directive

Today’s LB&I directive indicates that the de-coordination of any coordinated issue has no effect on whether the issue will continue to be pursued by LB&I in an examination or on the IRS’s views regarding any transaction, including listed transactions. This action follows LB&I’s review of all currently outstanding CIPs.


According to the directive, certain issues or procedures currently addressed in a CIP may be addressed in a future LB&I directive or other guidance. In addition, to the extent any CIP contained guidance (including tools) relevant to addressing a specific issue or transaction, the directive indicates that such guidance will be made available through the Issue Practice Group’s or International Practice Network’s intranet websites.


Internal Revenue Manual Part 4.51.2.4, which set forth procedures on CIPs, will be updated to reflect today’s LB&I directive.




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