The IRS today released an advance copy of Rev. Proc. 2016-19 concerning the “industry issue resolution” (IIR) program that is used to identify frequently disputed or burdensome tax issues that are common to a significant number of entities and that are resolved by the issuance of IRS guidance.
As explained in Rev. Proc. 2016-19 [PDF 58 KB] the purpose of the IIR program is to resolve issues shared by many taxpayers through pre-filing guidance rather than post-filing examination.
Previously, the IIR program was available for taxpayers under the jurisdiction of the Large Business and International (LB&I) and the Small Business and Self Employed (SB/SE) divisions of the IRS. Today’s revenue procedure announces that availability of the IIR program is being expanded with respect to issues under the jurisdiction of the Tax Exempt and Government Entities (TE/GE) division.
Today’s IRS release sets broad outlines of issues appropriate for the IIR program as well as issues that are not appropriate for the IIR program. Rev. Proc. 2016-19 also provides additional information about the program (such as the IRS procedures for establishing an IIR team to analyze the issues and develop guidance).
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