Split (1)

train · 2.89k rows

file_name stringlengths 6 21	description stringlengths 19 51	url stringlengths 38 53	text listlengths 1 625
iw2g.pdf	0121 Inst W-2G and 5754 (PDF)	https://www.irs.gov/pub/irs-pdf/iw2g.pdf	[ "Instructions for Forms\nW-2G and 5754\n(Rev. January 2021)\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nInformation about any future developments affecting Form W-2G \nor Form 5754 (such as legislation enacted after they were \npublished) will be posted at IRS.gov/FormW2G and IRS.gov/\nForm5754, respectively. Information about developments \naffecting these instructions will be posted on both pages.\nReminders\nIn addition to these specific instructions, you should also use the \ncurrent General Instructions for Certain Information Returns. \nThose general instructions include information about the \nfollowing topics.\n• Backup withholding.\n• Electronic reporting requirements.\n• Penalties.\n• When and where to file.\n• Taxpayer identification numbers.\n• Statements to recipients.\n• Corrected and void returns.\n• Other general topics.\nYou can get the general instructions at IRS.gov/\n1099GeneralInstructions.\nContinuous-use form and instructions. Form W-2G and its \ninstructions have been converted from an annual revision to \ncontinuous use. Both the form and instructions will be updated \nas needed. For the most recent version, go to IRS.gov/\nFormW2G.\nRegular withholding rate. The withholding rate under Section \n3402(q) applicable to winnings of $5,000 or more from \nsweepstakes, wagering pools, certain parimutuel pools, jai alai, \nand lotteries (formerly 25%) is 24%. This rate appears in the \nWithholding, Regular Gambling Withholding for Certain Games, \nNoncash payments, and Backup Withholding sections under \nSpecific Instructions for Form W-2G; the Withholding section \nunder 1. Horse Racing, Dog Racing, Jai Alai, and Other \nWagering Transactions Not Discussed Later; the Withholding \nsection under 2. Sweepstakes, Wagering Pools, and Lotteries; \nand the Withholding and Forms W-2G for Multiple Winners \nsection under Specific Instructions for Form 5754.\nBackup withholding rate. The backup withholding rate under \nSection 3406 applicable to certain winnings where the winner \ndoesn't furnish a correct taxpayer identification number (TIN) \n(formerly 28%) is 24%. This rate appears in the Withholding, \nRegular Gambling Withholding for Certain Games, and Backup \nWithholding sections under Specific Instructions for Form W-2G; \nthe Withholding section under 1. Horse Racing, Dog Racing, Jai \nAlai, and Other Wagering Transactions Not Discussed Later; \nand the Withholding section under 2. Sweepstakes, Wagering \nPools, and Lotteries.\nPayee identification rules. A payee of gambling winnings \nmeeting the reporting thresholds for bingo, keno, and slot \nmachines, and a payee of gambling winnings meeting the \nwithholding thresholds from horse racing, dog racing, jai alai, \nsweepstakes, wagering pools, lotteries, and certain other \nwagering transactions, but not from a state-conducted lottery, \nmust present two forms of identification, one of which must \ninclude the payee's photo. A completed and signed Form W-9 is \nacceptable as the nonphoto form of identification. Gaming \nestablishments owned or licensed by a tribal government of a \nfederally recognized Indian tribe may waive the photo ID \nrequirement for payees who are members of that tribe and \npresent a tribal member identification card issued by the same \ntribe. These rules affect boxes 11 and 12 under the instructions \nfor 1. Horse Racing, Dog Racing, Jai Alai, and Other Wagering \nTransactions Not Discussed Later; 2. Sweepstakes, Wagering \nPools, and Lotteries; and 3. Bingo, Keno, and Slot Machines.\nRules for determining the amount of the wager for certain \ngambling winnings. All wagers placed in a single parimutuel \npool and represented on a single ticket are aggregated and \ntreated as a single wager for purposes of determining the \namount of the wager with respect to winnings from parimutuel \nbetting on horse racing, dog racing, or jai alai. These rules affect \nboxes 1 and 4 under the instructions for Horse Racing, Dog \nRacing, Jai Alai, and Other Wagering Transactions Not \nDiscussed Later.\nAmounts paid with respect to identical wagers are treated as \npaid with respect to a single wager for purposes of calculating \nthe amount of proceeds from a wager. Two or more wagers are \nidentical wagers if winning depends on the occurrence (or \nnon-occurrence) of the same event or events; the wagers are \nplaced with the same payer; and, in the case of horse races, dog \nraces, or jai alai, the wagers are placed in the same parimutuel \npool. These rules affect boxes 1, 4, and 7 under the instructions \nfor Horse Racing, Dog Racing, Jai Alai, and Other Wagering \nTransactions Not Discussed Later; and for Sweepstakes, \nWagering Pools, and Lotteries.\nOptional reporting method for bingo, keno, and slot ma-\nchine winnings. A payer may use the optional aggregate \nreporting method to report more than one payment of reportable \ngambling winnings from bingo, keno, or slot machines received \nby a payee in a 24-hour calendar day or \"gaming day\" on a \nsingle information return. For more information, see the \ninstructions for box 1 under Bingo, Keno, and Slot Machines.\nSpecific Instructions for Form W-2G\nFile Form W-2G, Certain Gambling Winnings, to report gambling \nwinnings and any federal income tax withheld on those winnings. \nThe requirements for reporting and withholding depend on the \ntype of gambling, the amount of the gambling winnings, and \ngenerally the ratio of the winnings to the wager. File Form W-2G \nwith the IRS. You must provide a statement to the winner \n(Copies B and C of Form W-2G).\nThe types of gambling are discussed in these instructions \nunder the following four headings.\n \n1. Horse Racing, Dog Racing, Jai Alai, and Other Wagering \nTransactions Not Discussed Later.\n \n2. Sweepstakes, Wagering Pools, and Lotteries.\n \n3. Bingo, Keno, and Slot Machines. \n \n4. Poker Tournaments. \nReportable Gambling Winnings\nReport gambling winnings on Form W-2G if:\nFeb 18, 2021\nCat. No. 27989I\n", "1.\nThe winnings (not reduced by the wager) are $1,200 or \nmore from a bingo game or slot machine;\n2.\nThe winnings (reduced by the wager) are $1,500 or more \nfrom a keno game;\n3.\nThe winnings (reduced by the wager or buy-in) are more \nthan $5,000 from a poker tournament;\n4.\nThe winnings (except winnings from bingo, slot machines, \nkeno, and poker tournaments) reduced, at the option of the \npayer, by the wager are:\na.\n$600 or more, and\nb.\nAt least 300 times the amount of the wager; or\n5.\nThe winnings are subject to federal income tax \nwithholding (either regular gambling withholding or backup \nwithholding).\nTax-Exempt Organizations\nA tax-exempt organization conducting gaming activities may be \nrequired to withhold income tax and report on Form W-2G. See \nPub. 3079, Tax-Exempt Organizations and Gaming.\nWithholding\nThere are two types of withholding on gambling winnings: (a) \nregular gambling withholding at 24% (31.58% for certain \nnoncash payments), and (b) backup withholding that is also at \n24%. If a payment is already subject to regular gambling \nwithholding, it isn't subject to backup withholding.\nRegular Gambling Withholding for Certain Games\nYou may be required to withhold 24% of gambling winnings for \nfederal income tax. This is referred to as regular gambling \nwithholding. Withhold at the 24% rate if the winnings minus the \nwager are more than $5,000 and are from:\n• Sweepstakes;\n• Wagering pools;\n• Lotteries;\n• Wagering transactions in a parimutuel pool with respect to \nhorse races, dog races, or jai alai, if the winnings are at least 300 \ntimes the amount wagered; or\n• Other wagering transactions, if the winnings are at least 300 \ntimes the amount wagered.\nRegular gambling withholding doesn't apply to winnings from \nbingo, keno, or slot machines, nor does it apply to winnings from \nother wagering transactions if the winnings are $5,000 or less. \nHowever, see Backup Withholding, later.\nRegular gambling withholding is figured on the total amount \nof gross proceeds (the amount of winnings minus the amount \nwagered), not merely on the amount in excess of $5,000.\nReport the amount you withheld in box 4 of Form W-2G. Also, \nfile Form 945, Annual Return of Withheld Federal Income Tax, to \nreport all your gambling withholding.\nNoncash payments. You must take the fair market value \n(FMV) of a noncash payment, such as a car in a sweepstakes, \nwagering pool, or lottery, into account for purposes of reporting \nand withholding. If the FMV exceeds $5,000, after deducting the \nprice of the wager, the winnings are subject to 24% regular \ngambling withholding. The tax you must withhold is computed \nand paid under either of the following two methods.\n1.\nThe winner pays the withholding tax to the payer. In this \ncase, the withholding is 24% of the FMV of the noncash payment \nminus the amount of the wager.\n2.\nThe payer pays the withholding tax. In this case, the \nwithholding is 31.58% of the FMV of the noncash payment \nminus the amount of the wager.\nIf you use method 2, enter the sum of the noncash payment \nand the withholding tax in box 1 of Form W-2G and the \nwithholding tax paid by the payer in box 4.\nBackup Withholding\nYou may be required to withhold 24% of gambling winnings \n(including winnings from bingo, keno, slot machines, and poker \ntournaments) for federal income tax. This is referred to as \nbackup withholding. You should backup withhold if:\n• The winner doesn't furnish a correct taxpayer identification \nnumber (TIN),\n• Regular gambling withholding hasn't been withheld, and\n• The winnings are at least $600 and at least 300 times the \nwager (or the winnings are at least $1,200 from bingo or slot \nmachines or $1,500 from keno, or more than $5,000 from a \npoker tournament).\nFigure any backup withholding on the total amount of the \nwinnings reduced, at the option of the payer, by the amount \nwagered. This means the total amount, not just the payments in \nexcess of $600, $1,200, $1,500, or $5,000, is subject to backup \nwithholding.\nReport the amount you withheld in box 4 of Form W-2G. Also, \nfile Form 945 to report all backup withholding. You may use \nForm W-9, Request for Taxpayer Identification Number and \nCertification, to request the TIN of the recipient.\nSee the following instructions for each type of gambling for \ndetailed rules on backup withholding.\nForeign Persons\nPayments of gambling winnings to a nonresident alien individual \nor a foreign entity aren't subject to reporting or withholding on \nForm W-2G. Generally, gambling winnings paid to a foreign \nperson are subject to 30% withholding under sections 1441(a) \nand 1442(a) and are reportable on Form 1042, Annual \nWithholding Tax Return for U.S. Source Income of Foreign \nPersons, and Form 1042-S, Foreign Person's U.S. Source \nIncome Subject to Withholding. Winnings of a nonresident alien \nfrom blackjack, baccarat, craps, roulette, big-6 wheel, or a live \ndog or horse race in the United States from legal wagers initiated \noutside the United States in a parimutuel pool aren't subject to \nwithholding or reporting. See Pub. 515, Withholding of Tax on \nNonresident Aliens and Foreign Entities.\nState Tax Information\nBoxes 13, 14, and 15 and Copies 1 and 2 are provided for your \nconvenience only and don't have to be completed for the IRS. If \nyou withheld state income tax on a payment of gambling \nwinnings, you may enter it in box 15 of Form W-2G. If you do, \nalso complete boxes 13 and 14. A state identification number \n(box 13) is assigned by each individual state.\nIf a state tax department requires you to send it a paper copy \nof Form W-2G, use Copy 1 for that purpose. Give Copy 2 to the \nwinner for use in filing a state income tax return.\nLocal Tax Information\nBoxes 16, 17, and 18 and Copies 1 and 2 are provided for your \nconvenience only and don't have to be completed for the IRS. If \nyou withheld local income tax on a payment of gambling \nwinnings, you may enter it in box 17 of Form W-2G. If you do, \nalso complete boxes 16 and 18.\n-2-\nInstructions for Forms W-2G and 5754 (Rev. 01-2021)\n", "Form 5754\nIf the person receiving the winnings isn't the actual winner, or is a \nmember of a group of winners, see Specific Instructions for Form \n5754, later.\nStatements to Winners\nIf you are required to file Form W-2G, you must also provide a \nstatement to the winner. For information about the requirement \nto furnish a statement to the winner, see part M in the current \nGeneral Instructions for Certain Information Returns. You may \nfurnish Copies B and C of Form W-2G to the winner.\n1. Horse Racing, Dog Racing, Jai Alai, and Other \nWagering Transactions Not Discussed Later\nFile Form W-2G for every person to whom you pay $600 or more \nin gambling winnings if the winnings are at least 300 times the \namount of the wager. If the person presenting the ticket for \npayment is the sole owner of the ticket, complete Form W-2G \nshowing the name, address, and TIN of the winner. If regular \ngambling withholding is required, the winner must sign Form \nW-2G, under penalties of perjury, stating that he or she is the \nsole owner and that the information listed on the form is correct. \nIf more than one person shares in the winnings from a single \nwager, see Withholding and Forms W-2G for Multiple Winners, \nlater.\nWithholding\nYou must withhold federal income tax from the winnings if the \nwinnings minus the wager exceed $5,000 and the winnings are \nat least 300 times the wager. Withhold 24% of the proceeds (the \nwinnings minus the wager). This is regular gambling withholding.\nIf the winner of reportable gambling winnings doesn't provide \na TIN, you must backup withhold on any such winnings that \naren't subject to regular gambling withholding. The backup \nwithholding rate is identical to the regular withholding rate of \n24%. That is, backup withholding of 24% applies if the winnings \nare at least $600 but not more than $5,000 and are at least 300 \ntimes the wager. Figure backup withholding on the amount of the \nwinnings reduced, at the option of the payer, by the amount \nwagered.\nIdentical Wagers\nWinnings from “identical wagers” are added together for \npurposes of reporting and withholding requirements. Two or \nmore wagers are identical wagers if they are placed with the \nsame payer and winning depends on the occurrence (or \nnon-occurrence) of the same event or events. In the case of \nhorse races, dog races, or jai alai, wagers must also be placed in \nthe same parimutuel pool to be identical wagers. For example, \nmultiple bets placed in a parimutuel pool with a single payer on \nthe same horse to win a specific race are identical wagers.\nWagers in a Single Parimutuel Pool in Horse \nRacing, Dog Racing, or Jai Alai\nAll wagers in horse racing, dog racing, or jai alai placed in a \nsingle parimutuel pool and represented on a single ticket are \naggregated and treated as a single wager for purposes of \ndetermining the amount of the wager for withholding and \nreporting requirements. These types of wagers are not \nnecessarily identical wagers. For example, two bets in a single \nshow pool, one for Player X to show and the other for Player Y to \nshow, are not identical wagers because winning on the two bets \nisn't contingent on the occurrence of the same event. However, if \nboth bets are represented on a single ticket, then they must be \naggregated to determine the amount of the wager.\nBox 1\nEnter payments of $600 or more if the payment is at least 300 \ntimes the wager.\nBox 2\nEnter the date of the winning event. This isn't the date the money \nwas paid if it was paid after the date of the race (or game).\nBox 3\nEnter the type of wager if other than a regular race bet, for \nexample, Daily Double or Big Triple.\nBox 4\nEnter any federal income tax withheld, whether regular gambling \nwithholding or backup withholding.\nBox 5\nNot applicable.\nBox 6\nEnter the race (or game) applicable to the winning ticket.\nBox 7\nEnter the amount of additional winnings from identical wagers.\nBox 8 or 10\nEnter the cashier and/or window number making the winning \npayment.\nBox 9\nThis is required information. Enter the TIN of the person \nreceiving the winnings. For an individual, this will be the social \nsecurity number (SSN) or individual taxpayer identification \nnumber (ITIN). If the winner fails to give you a TIN, backup \nwithholding applies. See Withholding, earlier.\nBoxes 11 and 12\nAs verification of the name, address, and TIN of the person \nreceiving the winnings, enter the identification numbers from two \nforms of identification. Acceptable forms of identification include \na driver's license, passport, social security card, military \nidentification card, tribal member identification card issued by a \nfederally recognized Indian tribe, voter registration card, or \ncompleted and unmodified Form W-9. Enter the number and the \nstate or jurisdiction. In some instances, the number may be the \nsame number as in box 9.\nOne of the two forms of identification that the recipient \npresents must include the recipient's photograph. Gaming \nestablishments owned or licensed by a tribal government may \nwaive the photo ID requirement for payees who are members of \nthat federally recognized Indian tribe and present a tribal \nmember identification card issued by the same tribal \ngovernment.\nBoxes 13 Through 18\nThese boxes are provided for your convenience only and need \nnot be completed for the IRS. See State Tax Information and \nLocal Tax Information, earlier.\nBox 13. Enter the abbreviated name of the state and your state \nidentification number.\nInstructions for Forms W-2G and 5754 (Rev. 01-2021)\n-3-\n", "Box 14. Enter the amount of state winnings.\nBox 15. Enter the amount of state income tax withheld.\nBox 16. Enter the amount of local winnings.\nBox 17. Enter the amount of local income tax withheld.\nBox 18. Enter the name of your locality.\n2. Sweepstakes, Wagering Pools, and Lotteries\nFile Form W-2G for each person to whom you pay $600 or more \nin gambling winnings from a sweepstakes, wagering pool, or \nlottery (including a state-conducted lottery) if the winnings are at \nleast 300 times the amount of the wager. The wager must be \nsubtracted from the total winnings to determine whether \nwithholding is required and, at the option of the payer, to \ndetermine whether reporting is required. The wager must be \nsubtracted at the time of the first payment.\nThe requirements in this section apply to church raffles, \ncharity drawings, etc. In the case of one wager for multiple raffle \ntickets, such as five for $1, the wager is considered as $.20 for \neach ticket.\nWithholding\nYou must withhold federal income tax from the winnings if the \nwinnings minus the wager exceed $5,000. Withhold 24% of the \nproceeds (the winnings minus the wager). This is regular \ngambling withholding. If the winner of reportable gambling \nwinnings doesn't provide a TIN, you must backup withhold on \nany such winnings that aren't subject to regular gambling \nwithholding at the same withholding rate of 24%. That is, backup \nwithholding of 24% applies if the winnings are at least $600 but \nnot more than $5,000 and are at least 300 times the wager. \nFigure backup withholding on the amount of the winnings \nreduced, at the option of the payer, by the amount wagered.\nInstallment payments of $5,000 or less are subject to regular \ngambling withholding if the total proceeds from the wager will \nexceed $5,000.\nIf payments are to be made for the life of a person (or for the \nlives of more than one person), and it is actuarially determined \nthat the total proceeds from the wager are expected to exceed \n$5,000, such payments are subject to 24% regular gambling \nwithholding. When a third party makes the payments, for \nexample, an insurance company handling the winnings as an \nannuity, that third party must withhold.\nWhen Paid\nA payment of winnings is considered made when it is paid, either \nactually or constructively, to the winner. Winnings are \nconstructively paid when they are credited to or set apart for that \nperson without any substantial limitation or restriction on the \ntime, manner, or condition of payment. However, if not later than \n60 days after the winner becomes entitled to the prize, the \nwinner chooses the option of a lump sum or an annuity payable \nover at least 10 years, the payment of winnings is considered \nmade when actually paid. If the winner chooses an annuity, file \nForm W-2G each year to report the annuity paid during that year.\nIdentical Wagers\nWinnings from \"identical wagers\" are added together for \npurposes of the reporting and withholding requirements. Two or \nmore wagers are identical wagers if they are placed with the \nsame payer and winning depends on the occurrence (or \nnon-occurrence) of the same event or events.\nBox 1\nEnter payments of $600 or more if the payment is at least 300 \ntimes the wager.\nBox 2\nEnter the date of the winning transaction, such as the date of the \ndrawing of the winning number. This might not be the date the \nwinnings are paid.\nBox 3\nEnter the type of wager (such as raffle or 50-50 drawing) or the \nname of the lottery (such as Instant, Big 50, Baker's Dozen, or \nPowerball) and the price of the wager ($.50, $1, etc.).\nBox 4\nEnter any federal income tax withheld, whether regular gambling \nwithholding or backup withholding.\nBox 5\nFor a state lottery, enter the ticket number or other identifying \nnumber.\nBoxes 6, 8, and 10\nNot applicable.\nBox 7\nEnter the amount of additional winnings from identical wagers.\nBox 9\nThis is required information. Enter the TIN of the person \nreceiving the winnings. For an individual, this will be the social \nsecurity number (SSN) or individual taxpayer identification \nnumber (ITIN). If the winner fails to give you a TIN, backup \nwithholding applies. See Withholding under Sweepstakes, \nWagering Pools, and Lotteries, earlier.\nBoxes 11 and 12\nExcept for winnings from state lotteries, as verification of the \nname, address, and TIN of the person receiving the winnings, \nenter the identification numbers from two forms of identification. \nAcceptable forms of identification include a driver's license, \npassport, social security card, military identification card, tribal \nmember identification card issued by a federally recognized \nIndian tribe, voter registration card, or completed and \nunmodified Form W-9. Enter the number and the state or \njurisdiction. In some instances, the number may be the same \nnumber as in box 9.\nOne of the two forms of identification that the recipient \npresents must include the recipient's photograph. Gaming \nestablishments owned or licensed by a tribal government may \nwaive the photo ID requirement for payees who are members of \nthat federally recognized Indian tribe and present a tribal \nmember identification card issued by the same tribal \ngovernment.\nBoxes 13 Through 18\nThese boxes are provided for your convenience only and need \nnot be completed for the IRS. See State Tax Information and \nLocal Tax Information, earlier.\nBox 13. Enter the abbreviated name of the state and your state \nidentification number.\n-4-\nInstructions for Forms W-2G and 5754 (Rev. 01-2021)\n", "Box 14. Enter the amount of state winnings.\nBox 15. Enter the amount of state income tax withheld. \nBox 16. Enter the amount of local winnings.\nBox 17. Enter the amount of local income tax withheld.\nBox 18. Enter the name of your locality.\n3. Bingo, Keno, and Slot Machines\nFile Form W-2G for every person to whom you pay $1,200 or \nmore in gambling winnings from bingo or slot machines, or \n$1,500 or more from keno after the price of the wager for the \nwinning keno game is deducted. If the winnings aren't paid in \ncash, the FMV of the item won is considered the amount of the \nwinnings. Total all winnings from all wagers made during a single \nbingo or keno game to determine whether the winnings are \nreportable. Winnings and losses from other wagering \ntransactions aren't to be taken into account in arriving at the \n$1,200 or $1,500 figure.\nWithholding\nRegular gambling withholding doesn't apply to winnings from \nbingo, keno, or slot machines. However, if the recipient of \nreportable gambling winnings from bingo, keno, or slot machines \ndoesn't provide a TIN, you must backup withhold. That is, if the \nwinnings are at least $1,200 from bingo or slot machines or \n$1,500 from keno, backup withholding of 24% applies to the \namount of the winnings reduced, at the option of the payer, by \nthe amount wagered.\nBox 1\nEnter payments of $1,200 or more from bingo or slot machines \nor payments of $1,500 or more from keno.\nYou may use the optional aggregate reporting method to \nreport these payments. Under this method, aggregate multiple \npayments of reportable gambling winnings from bingo, keno, or \nslot machines received by a payee in a 24-hour calendar day or \n“gaming day” on a single Form W-2G. A “gaming day” is a \n24-hour period that ends at a particular time chosen by the \ngaming establishment (generally when the establishment is \nclosed or when business is slowest, such as between 3:00 a.m. \nand 6:00 a.m.). On December 31st, all open information \nreporting periods must close at 11:59 p.m. to end by the end of \nthe calendar year. On January 1st, all information reporting \nperiods must begin at 12:00 a.m. For more details and \nrecordkeeping requirements, see Regulations section \n1.6041-10(g).\nBox 2\nEnter the date of the winning transaction.\nBox 3\nEnter the type of wager (that is, bingo, keno, or slot machines) \nand the amount of the wager.\nBox 4\nEnter any backup withholding.\nBox 5\nEnter the ticket number, card number (and color, if applicable), \nmachine serial number, or any other information that will help \nidentify the winning transaction.\nBoxes 6 and 7\nNot applicable.\nBox 8\nEnter the initials of the person paying the winnings.\nBox 9\nThis is required information. Enter the TIN of the person \nreceiving the winnings. For an individual, this will be the social \nsecurity number (SSN) or individual taxpayer identification \nnumber (ITIN). If the winner fails to give you a TIN, backup \nwithholding applies. See Withholding under Bingo, Keno, and \nSlot Machines, earlier.\nBox 10\nEnter the location of the person paying the winnings, if \napplicable.\nBoxes 11 and 12\nAs verification of the name, address, and TIN of the person \nreceiving the winnings, enter the identification numbers from two \nforms of identification. Acceptable forms of identification include \na driver's license, passport, social security card, military \nidentification card, tribal member identification card issued by a \nfederally recognized Indian tribe, voter registration card, or \ncompleted and unmodified Form W-9. Enter the number and the \nstate or jurisdiction. In some instances, the number may be the \nsame number as in box 9.\nOne of the two forms of identification that the recipient \npresents must include the recipient's photograph. Gaming \nestablishments owned or licensed by a tribal government may \nwaive the photo ID requirement for payees who are members of \nthat federally recognized Indian tribe and present a tribal \nmember identification card issued by the same tribal \ngovernment.\nBoxes 13 Through 18\nThese boxes are provided for your convenience only and need \nnot be completed for the IRS. See State Tax Information and \nLocal Tax Information, earlier.\nBox 13. Enter the abbreviated name of the state and your state \nidentification number.\nBox 14. Enter the amount of state winnings.\nBox 15. Enter the amount of state income tax withheld.\nBox 16. Enter the amount of local winnings.\nBox 17. Enter the amount of local income tax withheld.\nBox 18. Enter the name of your locality.\n4. Poker Tournaments\nFile Form W-2G for each person to whom you pay more than \n$5,000 in winnings, reduced by the amount of the wager or \nbuy-in, from each poker tournament you have sponsored. \nWinnings and losses of the participant from other poker \ntournaments you have sponsored during the year aren't taken \ninto account in arriving at the $5,000 amount.\nWithholding and backup withholding. If you file Form W-2G \nfor the person to whom you pay more than $5,000 in net \nwinnings from a poker tournament, and provide a copy of Form \nW-2G to such person, regular gambling withholding doesn't \napply to the winnings. However, if the person who wins more \nthan $5,000 doesn't provide a TIN, you must apply backup \nInstructions for Forms W-2G and 5754 (Rev. 01-2021)\n-5-\n", "withholding to the full amount of the winnings from the \ntournament at the backup withholding rate of 24%. Net winnings \nof $5,000 or less aren't subject to reporting, withholding, or \nbackup withholding.\nBox 1\nEnter payments of more than $5,000 in net gambling winnings \nfrom a poker tournament.\nBox 2\nEnter the date of the poker tournament.\nBox 3\nEnter “poker tournament” in the entry space.\nBox 4\nEnter zero as the amount, unless the winning person hasn't \nprovided a TIN. If the winning person hasn't provided a TIN, \nenter the backup withholding amount.\nBox 5\nEnter the name of the tournament and its sponsor.\nBoxes 6 Through 8 and Box 10\nNot applicable.\nBox 9\nThis is required information. Enter the TIN of the person \nreceiving the winnings. For an individual, this will be the social \nsecurity number (SSN) or individual taxpayer identification \nnumber (ITIN). If the winner fails to give you a TIN, backup \nwithholding applies. See Withholding and backup withholding, \nearlier.\nBoxes 11 and 12\nAs verification of the name, address, and TIN of the person \nreceiving the winnings, enter the identification numbers from two \nforms of identification. Acceptable forms of identification include \na driver's license, social security card, or voter registration. Enter \nthe number and the state or jurisdiction. In some instances, the \nnumber may be the same number as in box 9.\nBoxes 13 Through 18\nThese boxes are provided for your convenience only and need \nnot be completed for the IRS. See State Tax Information and \nLocal Tax Information, earlier.\nBox 13. Enter the abbreviated name of the state and your state \nidentification number.\nBox 14. Enter the amount of state winnings.\nBox 15. Enter the amount of state income tax withheld.\nBox 16. Enter the amount of local winnings.\nBox 17. Enter the amount of local income tax withheld.\nBox 18. Enter the name of your locality.\nSpecific Instructions for Form 5754\nUse Form 5754, Statement by Person(s) Receiving Gambling \nWinnings, to prepare Form W-2G only when the person \nreceiving gambling winnings subject to reporting or withholding \nisn't the actual winner or is a member of a group of two or more \npeople sharing the winnings, such as by sharing the proceeds of \nthe same winning ticket. The payer is required to file Forms \nW-2G based on Form 5754.\nThe person receiving the winnings must furnish all the \ninformation required by Form 5754. However, a recipient of \nwinnings from a state-conducted lottery need not provide \nidentification other than his or her taxpayer identification number \n(TIN).\nPart I lists the identification of the person to whom the \nwinnings are paid, and Part II lists the actual winners, their \nrespective shares of the winnings, and any additional winnings \nfrom Identical Wagers. Identical wagers are defined earlier in the \nSpecific Instructions for Form W-2G.\nIn Part II, the person receiving the winnings must provide the \nname, address, TIN, respective share of the winnings, and \nadditional winnings from identical wagers for each of the \nwinners. In addition, if regular gambling withholding is required, \nthe form must be signed, under penalties of perjury, and dated \nby the person receiving the winnings.\nThe form must be returned to the payer for preparation of \nForm W-2G for each of the persons listed as winners. Forms \nW-2G may be issued immediately or by January 31 following the \nyear of the payment.\nDo not send Form 5754 to the IRS. Keep it for your records.\nWithholding and Forms W-2G for Multiple \nWinners\nIf more than one person shares in the winnings from a single \nwager, the total amount of the winnings (minus the amount \nwagered) will determine the amount of the proceeds for \npurposes of reporting and withholding. Do not allocate winnings \nto each winner before determining whether the withholding or \nreporting thresholds were reached.\nFor example, E purchases a sweepstakes ticket for $1 on \nbehalf of himself and S, who contributes an equal amount of the \nticket price and who will share equally in any winnings. The ticket \nwins $5,002. Because the winnings ($5,002 - $1 = $5,001) are \nmore than $5,000, you must withhold 24% of $5,001. You must \nprepare Form W-2G for E and a separate Form W-2G for S using \nthe information furnished to you on Form 5754.\n-6-\nInstructions for Forms W-2G and 5754 (Rev. 01-2021)\n" ]
p5489.pdf	0221 Publ 5489 (PDF)	https://www.irs.gov/pub/irs-pdf/p5489.pdf	[ "Publication 5489 (2-2021) Catalog Number 75380T Department of the Treasury Internal Revenue Service www.irs.gov\n❯ Taxpayers with income less than \n$56,844 in 2020 may be eligible to \nclaim the EITC.\n❯ The EITC can be as much as $6,660 \nfor a family with qualifying children.\n❯ Taxpayers who don’t have a qualifying \nchild could be eligible for up to $538.\nAffected taxpayers \ncan benefit from a \nnew Earned Income \nTax Credit rule \nIf the taxpayer earned less in 2020, \nthe rule may help them qualify for \na higher EITC refund. \nThis tax season, taxpayers may elect to \nuse their 2019 earned income to figure \nthe credit if their 2019 earned income is \nmore than their 2020 earned income.\nGenerally, earned income includes wages \nand net earnings from self-employment, \nas well as certain disability payments.\nThe same is true for the Additional \nChild Tax Credit. \nFor details, see the instructions for \nForm 1040 or Publication 596, Earned \nIncome Credit.\nThe EITC Assistant \ncan help determine \nwho is eligible. \nIRS.gov\n" ]
p5489sp.pdf	0221 Publ 5489 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5489sp.pdf	[ "Publication 5489 (sp) (2-2021) Catalog Number 75393W Department of the Treasury Internal Revenue Service www.irs.gov\n❯ Los contribuyentes con ingresos inferiores \nde $56,844 en 2020 pueden ser elegibles \npara reclamar el EITC. \n❯ El EITC puede ser de hasta $6,660 para una \nfamilia con hijos calificados.\n❯ Los contribuyentes que no tienen un \nhijo calificado podrían ser elegibles para \nhasta $538.\nContribuyentes \nafectados pueden \nbeneficiarse de nueva \nregla del Crédito \nTributario por Ingreso \ndel Trabajo (EITC) \nSi el contribuyente ganó menos en 2020, \nla regla puede ayudarlos a calificar para \nun reembolso mayor de EITC. \nEsta temporada de impuestos, los contribuy-\nentes pueden optar por usar sus ingresos del \ntrabajo de 2019 para calcular el crédito, si sus \ningresos del trabajo de 2019 fueron mayores \nque sus ingresos del trabajo de 2020. \nGeneralmente, los ingresos del trabajo incluyen \nsalarios y ganancias netas del trabajo por \ncuenta propia, así como ciertos pagos por \ndiscapacidad.\nLo mismo ocurre con el Crédito tributario \nadicional por hijos (en inglés). \nPara obtener más detalles, vea las instruc-\nciones del Formulario 1040 o de la Publicación \n596, Crédito por ingresos del trabajo.\nEl Asistente del \nEITC puede ayudar \na determinar quién \nes elegible. \nIRS.gov\n" ]
p4716.pdf	0920 Publ 4716 (PDF)	https://www.irs.gov/pub/irs-pdf/p4716.pdf	[ "When you use a tax preparer to help you file \nand claim the Earned Income Tax Credit (EITC), \nChild Tax Credit (CTC) or American Opportunity \nTax Credit (AOTC), take these items with you:\n•\t Driver’s license or other valid photo ID (if \nfiling a joint return, bring a photo ID for your \nspouse, and to e-file, both spouses must be \npresent to sign forms)\n•\t Valid Social Security card or verification of \nSocial Security number or other federal tax \nidentification number for all persons listed \non the return\n•\t Birth dates for all persons listed on the \nreturn\n•\t All statements for income received such \nas wages, unemployment, non-employee \ncompensation, interest, dividends, pension, \nSocial Security benefits, stock sales, or \nother income, and any statements showing \ntaxes withheld\n•\t If self-employed, records of all business \nincome and expenses\n•\t Records of expenses paid for higher \neducation including Forms 1098-T, Tuition \nStatement\n•\t Records of child and dependent care \nexpenses paid as well as the caregiver’s \nname, address and Social Security or other \nfederal tax identification number\n•\t Bank routing number and account number \nto directly deposit your refund\n•\t Copy of last year’s federal tax return if \navailable\nYour tax preparer, whether paid or volunteer, \nis required to ask questions to determine \nyour correct income, expenses, deductions \nand the amount of your credits and your \neligibility to claim them. Give your preparer \nall the needed information and answer \nall questions. A paid preparer must sign \nyour tax return and use a preparer tax \nidentification number.\nPublication 4716 (Rev. 9-2020) Catalog Number 74481V Department of the Treasury Internal Revenue Service www.irs.gov\nA federal tax REFUND may be waiting for you\nBe Prepared\n" ]
p5187.pdf	0221 Publ 5187 (PDF)	https://www.irs.gov/pub/irs-pdf/p5187.pdf	[ "PUBLICATION\n5187\nTax Year 2020\nAffordable Care Act: \n \nWhat You and Your \nFamily Need to Know\nIRS.gov (English)\nIRS.gov/Spanish (Español)\nIRS.gov/Chinese (中文)\nIRS.gov/Korean (한국어)\nGet forms and other information faster and easier at:\nIRS.gov/Russian (Pусский)\nIRS.gov/Vietnamese (TiếngViệt)\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n2\nTable of Contents\nIntroduction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3\nAffordable Care Act Overview. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4\nIndividual Shared Responsibility Provision.\n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5\nPremium Tax Credit and Advance Payments .\n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9\nU.S. Citizens Living Abroad . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15\nSummary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16\nGlossary. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n3\nIntroduction\nThis publication covers some of the tax provisions of the Affordable Care Act (ACA). It provides information about \nthe individual shared responsibility and the premium tax credit. A glossary is included to help taxpayers understand \nsome terms related to the health care law.\nWhat’s New?\nUnder the Tax Cuts and Jobs Act, passed December 22, 2017, the amount of the individual shared responsibility \npayment is reduced to zero for months beginning after December 31, 2018. \nBeginning in tax year 2019 and beyond, Forms 1040 and 1040-SR will not have the “full-year health care coverage or \nexempt” box and Form 8965, Health Coverage Exemptions, will no longer be used. \nYou need not make a shared responsibility payment or file Form 8965, Health Coverage Exemptions, with your tax \nreturn if you don’t have minimum essential coverage for part or all of the year.\nReminder from the IRS: If you need health coverage, visit HealthCare.gov to learn about health insurance options \nthat are available for you and your family, how to purchase health insurance, and how you might qualify to get \nfinancial assistance with the cost of insurance.\nTaxpayers who enrolled in coverage through the Health Insurance Marketplace during the calendar year and who \nreceived the benefit of advance payments of the premium tax credit (advance credit payments or APTC) must file \na tax return and reconcile any advance credit payments made on their behalf with the premium tax credit they are \nallowed. f you, your spouse if filing jointly, or a dependent received advance payments of the premium tax credit \nthrough the Health Insurance Marketplace, you must complete Form 8962, Premium Tax Credit. Filing your return \nwithout Form 8962 will delay your refund and may affect future advance credit payments.\nWhat forms may be used to prepare the return?\n\t\n●Form 1095-A, Health Insurance Marketplace Statement \n\t\n●Form 1095-B, Health Coverage \n\t\n●Form 1095-C, Employer-Provided Health Insurance Offer & Coverage\n\t\n●Form 8962, Premium Tax Credit, & Instructions\nForm 8965, Health Coverage Exemptions & Instructions, will not be available beginning in tax year 2019 and beyond. \nYou need not make a shared responsibility payment or file Form 8965 with your tax return if you don’t have minimum \nessential coverage for part or all of the year.\nTaxpayers, tax professionals, and volunteer preparers should consider preparing and filing tax returns electronically. \nUsing tax preparation software is an easy way to file a complete and accurate tax return as it does the math and \ncompletes the appropriate forms based on information provided by the taxpayer. Visit IRS.gov for information \nabout electronic filing options, including IRS Free File. The IRS Volunteer Income Tax Assistance (VITA) and the Tax \nCounseling for the Elderly (TCE) programs offer free tax help and e-file for taxpayers who qualify. Learn More About \nFree Tax Return Preparation\nWhat publications may be useful? \n\t\n●Publication 17, Your Federal Income Tax (For Individuals)\n\t\n●Publication 974, Premium Tax Credit\nThe IRS resource page on IRS.gov/aca is updated as new information is available.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n4\nAffordable Care Act Overview\nWhat is the Affordable Care Act?\nUnder the Affordable Care Act, the federal government, state governments, insurers, employers, and \nindividuals share responsibility for improving the quality and availability of health insurance coverage in the \nUnited States. \nThe ACA created the Health Insurance Marketplace, also known as the Marketplace. At the Marketplace, \nwhich may be a State-based or Federally-facilitated Marketplace, taxpayers can find information about \nhealth insurance options, enroll in qualified health plans and, if eligible, obtain help paying premiums and \nout-of-pocket costs. A taxpayer is allowed a premium tax credit only if the taxpayer, the taxpayer’s spouse if \nfiling a joint return or a member of the taxpayer’s family whom the taxpayer claims as a dependent enrolled \nin a qualified health plan through a Marketplace. This credit helps eligible taxpayers pay for coverage.\nThe ACA also includes the individual shared responsibility provision, which requires individuals to have \nqualifying health care coverage for each month of the year, qualify for a coverage exemption, or make a \nshared responsibility payment when filing their federal income tax returns. Under the Tax Cuts and Jobs Act, \npassed December 22, 2017, the amount of the individual shared responsibility payment is reduced to zero \nfor months beginning after December 31, 2018. \nFor purposes of the ACA, qualifying health care coverage is also called minimum essential coverage. Most \ntaxpayers already had minimum essential coverage prior to the start of the year and only had to maintain \nthat coverage during the entire year. Prior to tax year 2019, taxpayers and their dependents who had \nminimum essential coverage for each month of the year,simply checked a box on Form 1040 indicating that \ncoverage when they filed.\nSome taxpayers are exempt under the individual shared responsibility provision and, prior to tax year 2019, \nwould have filed Form 8965, Health Care Exemptions, to claim a coverage exemption. Beginning in tax year \n2019 and beyond, Forms 1040 and 1040-SR will not have the “full-year health care coverage or exempt” \nbox and Form 8965, Health Coverage Exemptions, will no longer be used as the shared responsibility \npayment is reduced to zero.\nYou need not make a shared responsibility payment or file Form 8965, Health Coverage Exemptions, with \nyour tax return if you don’t have minimum essential coverage for part or all of the year.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n5\nIndividual Shared Responsibility Provision\nWhat is the individual shared responsibility provision?\nFor each month of the year, the individual shared responsibility provision calls for individuals to have qualifying health \ncare coverage also called minimum essential coverage \nIndividuals are treated as having minimum essential coverage for the month as long as the individuals are enrolled \nin and entitled to receive benefits under a plan or program identified as minimum essential coverage for at least one \nday during that month.\nWho must have health care coverage?\nIn general, all U.S. taxpayers are subject to the individual shared responsibility provision. Under the provision, a \ntaxpayer must ensure that every nonexempt member of the tax household (that is, the taxpayer himself or herself, \nand for any individual the taxpayer could claim as a dependent for federal income tax purposes have minimum \nessential coverage). Thus, children must have minimum essential coverage or qualify for a coverage exemption for \neach month in the year. \nSenior citizens must also have minimum essential coverage for each month in the year. Both Medicare Part A and \nMedicare Part C (also known as Medicare Advantage) are minimum essential coverage. After Dec. 31, 2018, the \nshared responsibility payment is reduced to zero. Taxpayers age 65 or older will have the option to use new Form \n1040-SR, U.S. Tax Return for Seniors, when they file their federal income tax return. \nBeginning in tax year 2019 and beyond, Forms 1040 and Form 1040-SR will not have the “full-year health care \ncoverage or exempt” box and Form 8965, Health Coverage Exemptions, will no longer be used as the shared \nresponsibility payment is reduced to zero.\nYou need not make a shared responsibility payment or file Form 8965, Health Coverage Exemptions, with your tax \nreturn if you don’t have minimum essential coverage for part or all of the year. \nAll U.S. citizens are subject to the individual shared responsibility provision, as are all non-U.S. citizens who are in \nthe U.S. long enough during a calendar year to qualify as resident aliens for federal income tax purposes. Foreign \nnationals who live in the U.S. for a short enough period that they do not become resident aliens for tax purposes \nare exempt from the individual shared responsibility provision even though they may have to file a U.S. income tax \nreturn. In addition, all bona fide residents of U.S. territories are exempt from the individual shared responsibility \nprovision.\nWhat is minimum essential coverage? \nUnder the ACA, minimum essential coverage is a health care plan or arrangement specifically identified in the law as \nminimum essential coverage, including:\n\t\n●Specified government-sponsored programs (for example, Medicare Part A, Medicare Advantage, most \nMedicaid programs, CHIP\n, most TRICARE programs, and comprehensive health care coverage of veterans)\n\t\n●Employer-sponsored coverage under a group health plan (including self-insured plans)\n\t\n●Individual market coverage (for example, a qualified health plan purchased through the Marketplace or \nindividual health coverage purchased directly from an insurance company)\n\t\n●Grandfathered health plans (in general, certain plans that existed before the ACA and have not changed since \nthe ACA was passed)\n\t\n●Other plans or programs that the Department of Health and Human Services recognizes as minimum essential \ncoverage for purposes of the ACA\nIRS.gov/aca has a page that shows these and other types of coverage that qualify as minimum essential coverage \nand some that do not. \n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n6\nWill taxpayers report minimum essential coverage when they file?\nBeginning in tax year 2019 and beyond, Forms 1040 and 1040-SR will not have the “Full-year health care coverage \nor exempt” box and you will no longer report health care coverage when you file.\nSee prior year Form 8965 Instructions on IRS.gov for more information about minimum essential coverage, types of \ncoverage exemptions and the shared responsibility payment. If taxpayers owe a shared responsibility payment (SRP) \nfor tax years before 2019, the IRS may offset that liability with any tax refund that may be due to them.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n7\nHow will taxpayers claim coverage exemptions with the IRS?\nBeginning in tax year 2019 and beyond, Forms 1040 and 1040-SR will not have the “Full-year health care coverage \nor exempt” box and Form 8965, Health Coverage Exemptions, will no longer be available. Because the shared \nresponsibility payment for 2019 and subsequent years is reduced to zero, taxpayers need not affirmatively claim \ncoverage exemptions on their returns.\nWhat changes did the Tax Cuts and Jobs Act make to the individual shared responsibility \npayment?\nThrough tax year 2018, if anyone in the taxpayer’s tax household did not have minimum essential coverage, and did \nnot qualify for a coverage exemption, the taxpayer needed to make an individual shared responsibility payment when \nfiling a federal income tax return. \nEnacted in December 2017, the Tax Cuts and Jobs Act (TCJA) reduced the shared responsibility payment to zero for \ntax year 2019 and all subsequent years. For January 1, 2019 and beyond, taxpayers are still required by law to have \nminimum essential coverage or qualify for a coverage exemption. However, under the TCJA, you need not make a \nshared responsibility payment or file Form 8965 with your tax return if you don’t have minimum essential coverage \nfor part or all of the year.\nBeginning in 2019 and beyond, Forms 1040 and 1040-SR will not have the “Full-year health care coverage or \nexempt” box.\nReminder from the IRS: If you need health coverage, visit HealthCare.gov to learn about health insurance options \nthat are available for you and your family, how to purchase health insurance, and how you might qualify to get \nfinancial assistance with the cost of insurance.\nIf taxpayers owe a Shared Responsibility Payment for tax years before 2019, the IRS may offset that liability with any \ntax refund that may be due to them. The IRS routinely works with taxpayers who owe amounts they cannot afford to \npay. This sometimes includes enforced collection action such as liens and levies. However, the law prohibits the IRS \nfrom using liens or levies to collect any SRP\n. If taxpayers owe the SRP\n, the IRS may offset that liability with any tax \nrefund that may be due to them.\nWhat documentation will taxpayers receive?\nIf you, or another member of your tax household, were enrolled in health insurance during the year through a \nMarketplace, you will receive a statement from the Marketplace early in the new year relating to last year’s health \ninsurance coverage. If you or a family member enrolled in non-Marketplace coverage, the health coverage provider \nor employer through whom you enrolled may provide a statement to you with your health coverage information for \nyou, your spouse and any dependents. These forms will also be provided to the IRS.\nThe forms are:\n\t\n●Form 1095-A, Health Insurance Marketplace Statement \n\t\n●Form 1095-B, Health Coverage\n\t\n●Form 1095-C, Employer-Provided Health Insurance Offer and Coverage\nYou shouldn’t file these forms with your tax return but the information from them may help you complete your \ntax return. \nMost people will get at least one form; however, you may get more than one depending upon your circumstances. \nYou are likely to get more than one form if you had more than one insurance plan or if you worked for more than one \nemployer that offered coverage. You are also likely to get more than one form if you changed coverage or employers \nduring the year or if different members of your family received coverage from different providers. \n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n8\nWill I get a Form 1095-C from each of my employers?\nNot necessarily. You will only receive a Form 1095-C from your employer if the employer has 50 or more full-time \nor full-time equivalent employees. Most employers have fewer than 50 employees and therefore most employers \nare not required to issue Form 1095-C to their employees. Although you may receive multiple Forms 1095-C if you \nworked for two or more employers, it is possible that you will not receive a Form 1095-C from any of your employers.\nWhat do I do with these forms?\nMost people do not have to wait for these forms before filing their individual income tax return. The IRS has posted \na set of questions and answers about new Forms 1095-B and 1095-C. The questions and answers explain who \nshould expect to receive the forms, how they can be used, and how to file with or without the forms. \nHowever, if you, your spouse, or another person whom you claim as a dependent on your tax return enrolled in \ncoverage through a Health insurance Marketplace you will need the information on Form 1095-A to complete Form \n8962 and file a complete and accurate tax return. If you need a copy of your Form 1095-A, go to HealthCare.gov or \nyour state Marketplace website and log into your Marketplace account or call your Marketplace call center.\nIf you, your spouse, or another member of your tax household did not enroll in coverage through the Marketplace \nyou will not receive Form 1095-A and you do not need to wait for a Form 1095-B or Form 1095-C before you file. \nYou should carefully review any Forms 1095 that you subsequently receive to make sure they accurately reflect your \nhealth coverage for the year.\nTaxpayers who think they should have received a form but did not, need to get a replacement or need a corrected \nform, should contact the issuer directly: \n\t\n●Marketplace (Form 1095-A), \n\t\n●Coverage provider (Form 1095-B),\n\t\n●Employer (Form 1095-C).\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n9\nPremium Tax Credit and Advance Payments \nWho can claim a premium tax credit?\nOnly taxpayers who purchased a qualified health plan for themselves, their spouse if filing a joint return, or a person \nwhom they claim as a dependent on their tax return from a State-based or Federally-facilitated Health Insurance \nMarketplace are eligible for the premium tax credit. This tax credit helps eligible taxpayers pay their health insurance \npremiums. When enrolling themselves or a family member in a qualified health plan through the Marketplace, eligible \ntaxpayers may choose to have advance payments of the premium tax credit made to their insurance company \nor forego advance credit payments and wait to get the premium tax credit when they claim it on their tax return. \nTaxpayers must file a tax return to claim the premium tax credit. Those who choose advance credit payments \nmust file a tax return to reconcile their advance credit payments (the amount of which is based on a projection of \nhousehold income) with their actual premium tax credit (which is based on the taxpayer’s actual household income) \neven if they have gross income below the income tax filing threshold and they otherwise would not have to file a tax \nreturn.\nIn general, taxpayers are allowed a premium tax credit if they meet all of the following:\n\t\n●The taxpayer, or his or her spouse (if filing a joint return) or dependent was enrolled in a qualified health plan \noffered through the Marketplace for one or more months in which the enrolled individual was not eligible for \nother minimum essential coverage such as employer-sponsored coverage or government-sponsored coverage \nsuch as Medicaid or Medicare, and for which the taxpayer’s share of the enrollment premiums was paid by the \ndue date of the taxpayer’s return (not including extensions). \n\t\n●The taxpayer is an applicable taxpayer. A taxpayer is an applicable taxpayer if he or she meets the following \nthree requirements:\n•\t\nThe taxpayer’s household income is at least 100 percent, but not more than 400 percent, of the federal \npoverty line for the taxpayer’s family size. (See the exception below for taxpayers with household income \nbelow 100 percent of the federal poverty line who are not citizens, but are lawfully present in the U.S. See \nthe definition of “applicable taxpayer” in the glossary in this Publication for another exception for taxpayers \nwith household income below 100 percent of the federal poverty line for whom advance credit payments \nwere made.)\n•\t\nIf married, the taxpayer files a joint return with his or her spouse. If you are considered married for federal \nincome tax purposes, you may be eligible to take the PTC without filing a joint return if one of the two \nexceptions applies to you. If Exception 1 (Certain married persons living apart) applies, you can file a return \nusing head of household or single filing status and take the PTC. If Exception 2 (Victim of domestic abuse \nor spousal abandonment) applies, you are treated as married but can take the PTC with the filing status of \nmarried filing separately. See the glossary in this Publication for more information about domestic abuse or \nspousal abandonment and the instructions for Form 8962, Premium Tax Credit, for more details about these \nexceptions.\n•\t\nThe taxpayer cannot be claimed as a dependent by another person.\nA taxpayer with household income below 100 percent of the federal poverty line can be an applicable taxpayer if the \ntaxpayer, the taxpayer’s spouse, or a dependent who enrolled in a qualified health plan, is lawfully present in the U.S. \nand not eligible for Medicaid because of immigration status and the taxpayer meets the other applicable taxpayer \nrequirements.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n10\nFederal Poverty Line (FPL)\nThe federal poverty line (FPL) is an income amount (adjusted for family size considered poverty level for the year. \nThe U.S. Department of Health and Human Services (HHS) determines the federal poverty line amounts annually and \npublishes a table reflecting these amounts at the beginning of each calendar year. You can also find this information \non the HHS website at hhs.gov. HHS provides three federal poverty lines: \n\t\n●one for residents of the 48 contiguous states and D.C., \n\t\n●one for Alaska residents, and \n\t\n●one for Hawaii residents. \nFor purposes of the premium tax credit, eligibility for and the amount of the credit for a particular year is based on \nthe most recently published set of poverty guidelines as of the first day of the annual open enrollment period for \ncoverage in that year. The Federal poverty line for your family size is provided in Tables 1-1, 1-2, and 1-3, in the Form \n8962, Premium Tax Credit, instructions. \nWhat is household income and what are its limits?\nA taxpayer’s household income is the total of the taxpayer’s modified adjusted gross income (MAGI), the taxpayer’s \nspouse’s MAGI if married filing a joint return, and the MAGI of all dependents required to file a federal income tax \nreturn because the dependent’s income meets the income tax return filing threshold. \nMAGI, for the purpose of the premium tax credit, is the adjusted gross income on the federal income tax return plus \nany excluded foreign income, nontaxable social security benefits (including tier 1 railroad retirement benefits), and \ntax-exempt interest. It does not include Supplemental Security Income (SSI).\nIn general, only taxpayers and families whose household income for the year is between 100 percent and 400 \npercent of the federal poverty line for their family size may be eligible for the premium tax credit. A taxpayer who \nmeets these income requirements must also meet the other eligibility criteria to claim the premium tax credit. \nAre taxpayers allowed a premium tax credit for all enrolled family members?\nA taxpayer is allowed a premium tax credit only for months that (1) a member of the taxpayer’s tax family is enrolled \nin a qualified health plan offered through a Marketplace and is not eligible for minimum essential health coverage \n(other than individual market coverage), and (2) the taxpayer’s share of the enrollment premium for the month is paid \nby the due date of the taxpayer’s return (not including extensions). The taxpayer’s tax family consists of the taxpayer, \nthe taxpayer’s spouse if filing jointly, and all other individuals whom the taxpayer claims as dependents. The family \nmembers who meet the first requirement above are the taxpayer’s “coverage family.” For example, if an individual \nchanged enrollment from Marketplace coverage to employer-sponsored coverage during the year, the individual is \na member of the coverage family only for the months the individual is enrolled through the Marketplace and was \nnot eligible for coverage under the employer-sponsored plan or other coverage (not counting individual market \ncoverage).\nIs a taxpayer allowed a premium tax credit for the coverage of a family member if the family member enrolls in \nemployer coverage?\nGenerally, a premium tax credit is not allowed for a person’s Marketplace coverage for those months in which the \nperson is eligible for employer-sponsored coverage, even if the person turns down the employer’s coverage. This \nincludes the employee and a family member of the employee who is eligible to enroll in the employer coverage as a \nresult of a relationship to the employee. A person may be allowed a premium tax credit despite an offer of employer \ncoverage if the employer’s coverage is unaffordable or fails to meet a minimum value standard (employers will \nprovide employees with information concerning whether the minimum value standard is met). However, a premium \ntax credit is not allowed for the months an individual is enrolled in employer coverage, even if the employer coverage \nis unaffordable or fails to meet the minimum value standards.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n11\nWhen is employer coverage considered to be affordable for an individual?\nIn general, the determination of whether employer coverage is affordable is made by comparing the employee’s cost of \nthe employer coverage for self-only coverage to household income. For plan years beginning in 2020, if the employee’s \ncost for the employer coverage is more than 9.78 percent of household income, the employer coverage is unaffordable. \nThe affordability test for family members is the same as the test for the employee (compare the cost of the employee’s \nself-only coverage to household income). However, if during the Marketplace application process, the Marketplace \ndetermines that, based on projected household income, the employer coverage would be unaffordable, the employer \ncoverage is considered unaffordable for the employer’s plan year even if it would have been affordable based on the \nhousehold income reported on the tax return. \nIs a taxpayer allowed the premium tax credit for a family member’s coverage if the family member is eligible for \ncoverage through a government-sponsored program?\nAn individual eligible for coverage through a government-sponsored program such as Medicaid, Medicare, CHIP or \nTRICARE, is not a member of the coverage family for the months in which the individual is eligible for government- \nsponsored coverage. Therefore, a premium tax credit is not allowed for this individual’s coverage for the months \nthe individual is eligible for the government-sponsored coverage. However, an individual is treated as not eligible for \nMedicaid, CHIP\n, or a similar program for a period of coverage under a qualified health plan if, when the individual \nenrolls in the qualified health plan, the Marketplace determines or considers the individual to be not eligible for \ncoverage under the program.\nA person is considered eligible for government or employer-sponsored coverage for a month only if the person is \neligible for the coverage for every day of that month. For example, if a person becomes eligible for employer or \ngovernment-sponsored coverage on the 5th day of a month, he or she is considered not eligible for the employer or \ngovernment coverage for that month and may be allowed a premium tax credit for the month. The person will not \nbe eligible for the premium tax credit for the following month. Thus, the person should alert the Marketplace to the \nchange and discontinue any advance credit payments for the Marketplace coverage.\nHow does the taxpayer get advance payments of the premium tax credit?\nDuring enrollment in a Marketplace health plan, a taxpayer projects his or her household income and family \ncomposition. The Marketplace verifies this information through various data sources, including prior year tax \ninformation, Social Security Administration data, and state-level wage data. Using all of this information, the \nMarketplace estimates the amount of premium tax credit the taxpayer will be able to claim. This estimate of the \npremium tax credit is the maximum amount of advance credit payments for which the taxpayer is eligible.\nIf eligible for advance credit payments of the premium tax credit, taxpayers may choose to:\n\t\n●Have some or all of the maximum amount of advance credit payments for which the taxpayer is eligible paid \ndirectly to the insurance company to lower what is paid out-of-pocket for monthly premiums; or \n\t\n●Forego advance credit payments, pay the entire amount of the monthly premiums and get the credit when they \nfile their tax return.\nThe amount of the advance credit payments will appear on Form 1095-A, Health Insurance Marketplace Statement, \nissued by the Marketplace.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n12\nHow is the amount of the premium tax credit determined?\nThe premium tax credit is the sum of the credit amount for each month. The credit amount for a month is the lesser \nof two amounts: (1) the monthly premium for the plan or plans in which the taxpayer’s family enrolled (enrollment \npremium) and (2) the monthly premium for the taxpayer’s applicable second lowest cost silver plan (SLCSP) minus \nthe taxpayer’s monthly contribution amount. This calculation is done on Form 8962, Premium Tax Credit. The \napplicable SLCSP premium will generally be determined by the Marketplace and included on Form 1095-A. Health \nInsurance Marketplace Statement. A taxpayer’s monthly contribution amount is 1/12 of the product of the taxpayer’s \nhousehold income by the applicable figure (from Table 2 in the instructions for Form 8962). The applicable figure is \ndetermined on the basis of the ratio that the taxpayer’s household income bears to the federal poverty line for the \ntaxpayer’s family size. The monthly contribution amount is the contribution amount divided by 12. Taxpayers enrolled \nin the same qualified health plan for all 12 months of the year and who have the same applicable SLCSP for all 12 \nmonths can do a single, annual calculation to compute their premium tax credit.\nTaxpayers who receive a Form 1095-A, Health Insurance Marketplace Statement, from the Marketplace showing \nchanges in monthly amounts must do a monthly calculation to determine their premium tax credit in Section 2 of \nForm 8962, Premium Tax Credit. Taxpayers who have changes in monthly amounts not shown on Form 1095-A (for \nexample, a taxpayer enrolled in a qualified health plan became eligible for employer coverage during the year, but did \nnot notify the Marketplace) must also do a monthly calculation to determine their premium tax credit. \nThe premium tax credit is a refundable tax credit. If the amount of the credit is more than the amount of the tax \nliability on the return, taxpayers will receive the difference as a refund. If no tax is owed, taxpayers can get the full \namount of the credit as a refund. \nIf taxpayers received the benefit of advance credit payments, they will reconcile the advance credit payments with \nthe amount of the actual premium tax credit that is calculated on the tax return. If excess advance credit payments \nwere made on their behalf (meaning the advance credit payments are more than the amount of the premium tax \ncredit), taxpayers will enter the excess advance credit payment amount on their return and repay all or a portion of it \nwhen they file their federal income tax return. \nWhat happens if income or family size changed during the year?\nPart of the premium tax credit calculation is the contribution amount, which will be higher at a higher FPL (and lowers \nthe amount of the credit). FPL is based on household income and family size. Therefore, a taxpayer’s premium \ntax credit for the year will differ from the amount of advance credit payments estimated by the Marketplace if the \ntaxpayer’s family size or household income as estimated at the time of enrollment is different from the family size or \nhousehold income reported on the return. \nA taxpayer’s premium tax credit for the year typically will differ from the advance credit payment amount estimated \nby the Marketplace because the taxpayer’s family size and household income are estimated at the time of \nenrollment. The more the actual family size or household income differs from the estimates the Marketplace used \nto compute the advance credit payments, the more significant the difference will be between the advance credit \npayments and the actual credit. In addition, changes to a taxpayer’s coverage family can result in differences \nbetween the taxpayer’s advance credit payments and premium tax credit (for example, an excess advance credit \npayment will likely arise if a member of the taxpayer’s coverage family becomes eligible for employer coverage \nduring the year but the taxpayer does not notify the Marketplace of the change).\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n13\nTaxpayers should notify the Marketplace about changes in circumstances when they happen, which allows the \nMarketplace to update the information used to determine the expected amount of the premium tax credit and adjust \nthe advance credit payment amount. This adjustment decreases the likelihood of a significant difference between the \nadvance credit payments and the actual premium tax credit. Changes in circumstances that can affect the amount of \nthe actual premium tax credit include:\n\t\n●Increases or decreases in household income\n\t\n●Marriage or divorce\n\t\n●Birth or adoption of a child or other changes in household composition\n\t\n●Gaining or losing eligibility for government-sponsored or employer-sponsored health care coverage\n\t\n●Change of address\nWhat documentation will taxpayers receive?\nBy January 31 of the year following the year of coverage, the Marketplace will send a Form 1095-A, Health Insurance \nMarketplace Statement, to taxpayers who enrolled themselves, or a person whom they claim as a dependent, in \ninsurance through the Marketplace. The information statement includes the monthly premium for the applicable \nSLCSP used to compute the credit, the monthly enrollment premiums (the premiums for the plan or plans the \ntaxpayer and his or her family members enrolled in), the amount of the advance credit payments, the SSN and \nnames for all covered individuals, and all other required information. The Marketplace also reports this information to \nthe IRS.\nTaxpayers will use the information on Form 1095-A, Health Insurance Marketplace Statement, to compute the \npremium tax credit on their tax return and to reconcile the advance credit payments made on their behalf with the \namount of the actual premium tax credit on Form 8962. \nWhat do taxpayers do if they lost or never received their Form 1095-A or if it is incorrect?\nIf Form 1095-A was lost, never received, or is incorrect, taxpayers should contact their Marketplace directly for a \ncopy. Information regarding how to reach the Marketplace is available on HealthCare.gov as well as IRS.gov/aca. \nIf taxpayers experience difficulty obtaining the Form 1095-A, Health Insurance Marketplace Statement, from their \nMarketplace, they should review the monthly billing statements provided by their health coverage provider or contact \nthe provider directly to obtain the coverage information, monthly premium amounts, and amount of monthly advance \ncredit payments made on their behalf.\nHow is the premium tax credit claimed on the tax return?\nOnly taxpayers who enrolled themselves, their spouse if filing a joint return, or a person whom they claim as \ndependent, in a qualified health plan through the Marketplace are allowed a premium tax credit. Taxpayers claim \nthe premium tax credit on their federal income tax return. Taxpayers who received the benefit of advance credit \npayments must file a federal income tax return even if they otherwise are not required to file a tax return. \nA taxpayer computes the amount of PTC on Form 8962 and reconciles it with the advance credit payments for the \nyear. On Form 8962, Premium Tax Credit, a taxpayer must subtract the advance credit payments for the year from \nthe amount of the taxpayer’s premium tax credit calculated on the tax return. If the premium tax credit computed on \nthe return is more than the advance credit payments made on the taxpayer’s behalf during the year, the difference \nwill increase the taxpayer’s refund or lower the amount of tax owed. This will be reported in Form 1040, Schedule 3. \nIf the advance credit payments are more than the premium tax credit (an excess advance credit payment), all or a \nportion of the difference will increase the amount of the taxpayer tax liability and result in either a smaller refund or \ntaxes owed. This will be entered in Form 1040, Schedule 2.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n14\nFor taxpayers with household income below 400 percent of the FPL, the amount of tax liability due to excess \nadvance credit payments is limited as provided in the repayment limitation table (see below). \nRepayment Limitation Table\nHousehold Income Percentage of Federal Poverty Line\nLimitation Amount \nfor Single\nLimitation Amount for \nAll Other Filing Statuses\nLess than 200%\n$300\n$600\nAt least 200%, but less than 300%\n$800\n$1,600\nAt least 300%, but less than 400%\n$1,325\n$2,650\n400% or more\nNo limit\nNo limit\nConsult the instructions for Form 8962, Premium Tax Credit Credit, and Publication 974, Premium Tax Credit, for \nmore information. For taxpayers eligible to use the Married Filing Separately filing status, the repayment limitation \nabove applies to the spouses separately based on the household income reported on each return. \nTaxpayers who chose not to have advance credit payments made on their behalf during the tax year will get all of the \nbenefit of their premium tax credit on their tax return. This will either increase their refund or lower the taxes owed. \nWhat about unusual situations?\nFor situations listed below, consult the instructions for Form 8962, Premium Tax Credit Credit, and Publication 974, \nPremium Tax Credit.\nWhat if taxpayers have a shared policy purchased through the Marketplace?\nIf a taxpayer, or another member of the taxpayer’s tax family, is enrolled in a policy with a person not in the \ntaxpayer’s tax family (a shared policy), the taxpayer may have to allocate the items on Form 1095-A, Health \nInsurance Marketplace Statement (the enrollment premium, the premium for the applicable SLCSP\n, and the advance \ncredit payments) with another taxpayer (a shared policy allocation). The following taxpayers may have to do a shared \npolicy allocation: \n\t\n●Taxpayers who got divorced or legally separated in during the tax year\n\t\n●A taxpayer who claims as a dependent an individual (the taxpayer’s child, for example) who was enrolled in a \npolicy with an individual in another taxpayer family (the taxpayer’s former spouse, for example)\n\t\n●A taxpayer who is enrolled in a policy with an individual (the taxpayer’s child, for example) who is claimed as a \ndependent by another taxpayer (the taxpayer’s former spouse, for example).\n\t\n●A taxpayer filing a separate return from his or her spouse \nTaxpayers complete the shared policy allocation on Form 8962, Premium Tax Credit, Part 4. \nWhat if taxpayers get married during the year?\nIf taxpayers got married during the tax year and one or both spouses received the benefit of advance credit \npayments for the year, the spouses may be eligible to use an alternative calculation to determine their excess \nadvance credit payments. The alternative calculation will generally allocate half of the adjusted gross income on the \nreturn to each spouse and can be used to reduce excess advance credit payments, but not to increase net PTC.\nSee the instructions for Form 8962, Premium Tax Credit, for eligibility. If eligible, taxpayers will complete Form 8962, \nPart 5, Alternative Calculation of Year of Marriage.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n15\nU.S. Citizens Living Abroad \nHow does the Affordable Care Act affect U.S. citizens living abroad?\nU.S. citizens living abroad are subject to the individual shared responsibility provision. However, U.S. citizens who \nare not physically present in the United States for at least 330 full days within a 12-month period are treated as \nhaving minimum essential coverage for that 12-month period regardless of whether they enroll in any health care \ncoverage. \nIn addition, U.S. citizens who are bona fide residents of a foreign country (or countries) for an entire taxable year \nare treated as having minimum essential coverage for that year. In general, these individuals qualify for the foreign \nearned income exclusion under section 911.\nIndividuals may qualify for this rule even if they cannot use the section 911 exclusion for all of their foreign earned \nincome because, for example, they are employees of the United States. Individuals that qualify for this rule need take \nno further action to comply with the individual shared responsibility provision during the months when they qualify. \n \u0007\nSee Publication 54, Tax Guide for US Citizens and Resident Aliens Abroad, for further information on the \nforeign earned income exclusion \nU.S. citizens who do not meet the physical presence or residency requirements must have minimum essential \ncoverage, qualify for a coverage exemption, or make an individual shared responsibility payment when they file \ntheir federal income tax returns. Note that minimum essential coverage includes a group health plan provided by an \noverseas employer. \nWhat about individuals not lawfully present?\nThe premium tax credit is not allowed for the coverage of an individual who is not lawfully present in the United \nStates. Further, taxpayers must increase their tax liability to the extent of all advance credit payments made for a not \nlawfully present individual. If a member of the family is not lawfully present and is enrolled in a qualified health plan \nwith family members who are lawfully present for one or more months of the year, use the instructions in Publication \n974 to find out the amount of advance credit payments, if any, that must be repaid. If all family members enrolled in \na qualified health plan are not lawfully present, the tax liability must be increased to the extent of all of the advance \ncredit payments made for the coverage of the family members. There is no repayment limitation on excess advance \ncredit payments attributable to the coverage of an individual not lawfully present in the United States. Complete \nForm 8962 as directed in Publication 974.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n16\nSummary\nThe individual shared responsibility provision requires every U.S. taxpayer and their dependent(s) to have qualifying \nhealth care coverage, also called minimum essential coverage. \nHowever, beginning in tax year 2019 and subsequent years, taxpayers will no longer report minimum essential \ncoverage, report or claim exemptions, or make any individual shared responsibility payment when filing their federal \nincome tax return as the Tax Cuts & Jobs Act reduces the individual shared responsibility payment to zero.\nIf a taxpayer or a member of the taxpayer’s family enrolled in a qualified health plan through the Marketplace, the \ntaxpayer must reconcile any advance credit payments with their actual premium tax credit on Form 8962, Premium\t\nTax Credit. If excess advance credit payments were made on a taxpayer’s behalf, the taxpayer will enter the excess \namount of advance credit payments on the tax return and increase tax liability by the excess, subject to a repayment \ncap if the taxpayer’s household income is under 400% of the FPL, when filing his or her federal income tax return.\nTaxpayers who enrolled themselves, their spouse if filing a joint return, or a person whom they claim as a dependent, \nin a qualified health plan through a Marketplace will receive Form 1095-A, Health Insurance Marketplace Statement. \nThe Form 1095-A will contain the information necessary to complete Form 8962, Premium Tax Credit.\nThe net premium tax credit is claimed in the Payments section of the federal income tax return. Any excess advance \ncredit payments are entered in the Tax and Credits section of the federal income tax return.\nPremium Tax Credit Online Tools\nThe IRS has an online tool to help you determine if you are eligible for the premium tax credit. Use the Am I eligible to \nclaim the Premium Tax Credit? Interactive Tax Assistant tool on IRS.gov. \nTaxpayer Advocate Service also has a Premium Tax Credit Change Estimator tool to assist with figuring eligibility \nand estimating that credit amount as well.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n17\nGlossary\nApplicable taxpayer (for purpose of premium tax credit) – A taxpayer must be an applicable taxpayer to claim \nthe premium tax credit (PTC). Generally, an applicable taxpayer is one who has household income of at least 100 \npercent but not more than 400 percent of the Federal poverty line (FPL) for the family size, and cannot be claimed as \na dependent. If the taxpayer is married at the end of the year, the taxpayer must file a joint return to be an applicable \ntaxpayer unless an exception is met. \nA taxpayer with household income below 100 percent of the FPL is an applicable taxpayer if all of the following \nrequirements are met:\n\t\n●The taxpayer, the taxpayer’s spouse or a dependent enrolled in a qualified heath plan through a Marketplace.\n\t\n●The Marketplace estimated at the time of enrollment that the taxpayer’s household income would be between \n100 percent and 400 percent of the FPL for the taxpayer’s family size. \n\t\n●Advance credit payments were made for the coverage for one or more months during the year.\n\t\n●The taxpayer otherwise qualifies as an applicable taxpayer.\nA taxpayer with household income below 100 percent of the FPL can be an applicable taxpayer as long as the \ntaxpayer, the taxpayer’s spouse, or a dependent who enrolled in a qualified health plan is not a U.S. citizen but is \nlawfully present in the U.S. and not eligible for Medicaid because of immigration status.\nCoverage Family – The coverage family includes all members of the taxpayer’s tax family (the taxpayer, the \ntaxpayer’s spouse if filing a joint return, and the taxpayer’s dependents) who are enrolled in a qualified health plan \nand are not eligible for minimum essential coverage (other than coverage in the individual market). (See below for \nthe definition of the individual market.) The members of the coverage family may change from month to month. A \ntaxpayer is allowed a premium tax credit only for health insurance purchased for members of the coverage family.\nDomestic abuse – Domestic abuse includes physical, psychological, sexual, or emotional abuse, including efforts \nto control, isolate, humiliate, and intimidate, or to undermine the victim’s ability to reason independently. All the facts \nand circumstances are considered in determining whether an individual is abused. Abuse of the victim’s child or any \nfamily member living in household may constitute abuse of the victim. \nExchange – See Marketplace. \nFamily size – Family size is the number of individuals in the taxpayer’s tax family.\nFederal Poverty Line (FPL) – FPL is an income amount considered poverty level for the year, adjusted for family \nsize. The Department of Health and Human Services (HHS) determines the federal poverty guideline amounts \nannually. The government adjusts the income limits annually for inflation.\nForm 1095-A, Health Insurance Marketplace Statement – Form 1095-A is used to report certain information to \nthe IRS about individuals who enroll in a qualified health plan through a Marketplace. Form 1095-A, Health Insurance \nMarketplace Statement, also is furnished to individuals to allow them to claim the premium tax credit, to reconcile \nthe credit on their returns with advance payments of the premium tax credit (advance credit payments), and to file an \naccurate tax return.\nForm 1095-B, Health Coverage – Form 1095-B is used to report certain information to the IRS and to taxpayers \nabout individuals who are covered by minimum essential coverage and therefore are not liable for the individual \nshared responsibility payment. Most taxpayers will receive Form 1095-B beininng in 2016 for coverage in 2015.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n18\nForm 1095-C, Employer Provided Health Insurance Offer and Coverage – Employers with 50 or more full-time \nemployees use Form 1095-C to report information about offers of health coverage and enrollment in health coverage \nfor their employees. Form 1095-C is used to report information about each employee. Taxpayers will receive Form \n1095-C beginning in 2016 for employer coverage offered in 2015.\nHealth Insurance Marketplace – See Marketplace.\nHousehold income – The sum of the taxpayer’s modified adjusted gross income (MAGI), the spouse’s MAGI (if \nMarried Filing Jointly), and the MAGI of all dependents required to file a tax return, because the dependent’s income \nmeets the income tax return filing threshold. \nIncarceration – The taxpayer can claim a coverage exemption for a member of the tax household for any month in \nwhich the individual was incarcerated for at least 1 day in the month. An individual is incarcerated if he or she was \nconfined, after the disposition of charges, in a jail, or similar penal institution or correctional facility.\nIndividual market – The insurance market that provides private, individual (non-group) health insurance coverage \nto individuals who purchase health insurance on their own. This includes qualified health plans offered through \nthe Marketplace. Each individual generally must pay the entire cost of the health insurance premium, but certain \nindividuals may be eligible for insurance premium subsidies for coverage offered through the Marketplace. \nMAGI – See Modified Adjusted Gross Income.\nMarketplace (also: Exchange, Health Insurance Marketplace) – A governmental agency or nonprofit entity that \nmakes qualified health plans available to individuals. The term “Marketplace” refers to state Marketplaces, regional \nMarketplaces, subsidiary Marketplaces, and a federally-facilitated Marketplace.\nMarried taxpayers (for purposes of the premium tax credit) – If a taxpayer is married at the end of a tax year, the \ntaxpayer generally must file a joint return with his or her spouse to claim the premium tax creditfor the tax year. A \njoint return is not required if the taxpayer meets one of the two exceptions below: \n\t\n●Exception 1 (Head of Household filing status). If taxpayer was not divorced or legally separated at the end of \nthe year, he or she is considered unmarried if all of the following apply:\n•\t\nThe taxpayer lived apart from spouse for the last 6 months of the year. (Temporary absences for special \ncircumstances, such as for business, medical care, school, or military service, count as time lived in the \nhome.)\n•\t\nThe taxpayer filed a separate return from spouse.\n•\t\nThe taxpayer paid over half the cost of keeping up his or her home for the year.\n•\t\nThe taxpayer home was the main home of the taxpayer’s child, stepchild, or foster child for more than half \nof the year. (Temporary absences for special circumstances, such as for school, vacation, medical care, \nmilitary service, and detention in a juvenile facility, count as time lived in home.)\n•\t\nThe taxpayer can claim the child as a dependent or could claim the child as a dependent except that the \nchild’s other parent can claim him or her under the rule for children of divorced or separated parents.\n\t\n●Exception 2. If taxpayer is a victim of domestic abuse or abandonment and does not qualify to use Head of \nHousehold filing status, the taxpayer may claim a premium tax credit if he or she files a return as Married Filing \nSeparately and meets the following:\n•\t\nThe taxpayer is living apart from his or her spouse at the time the taxpayer filed the current year tax return.\n•\t\nThe taxpayer is unable to file a joint return because he or she is a victim of domestic abuse or spousal \nabandonment.\n•\t\nThe taxpayer certifies on the return that the taxpayer is a victim of domestic abuse or spousal \nabandonment.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n19\nMedicaid expansion – The health care law provides states with additional federal funding to expand their Medicaid \nprograms to cover adults under 65 who make up to 138 percent of the federal poverty level. Children (18 and under) \nare eligible up to that income level or higher in all states.\nThe U.S. Supreme Court ruled that the Medicaid expansion is voluntary with states. As a result, some states have \nnot expanded their Medicaid programs. Many adults in those states with incomes below 100 percent of the federal \npoverty level fall into a gap. Their incomes are too high to get Medicaid under their state’s current rules but their \nincomes are too low to qualify for the premium tax credit.\nMinimum essential coverage (MEC) – Coverage under a government-sponsored program, an eligible employer-\nsponsored plan, a plan in the individual market, a grandfathered health plan, or other coverage recognized by the \nDepartment of Health and Human Services (HHS), in coordination with the Secretary of the Treasury, as minimum \nessential coverage. \nModified Adjusted Gross Income (MAGI) (for purposes of the premium tax credit) – MAGI is a taxpayer’s \nadjusted gross income plus certain income that is not subject to tax (foreign earned income, tax-exempt interest, \nand social security benefits not included in income).\nPremium tax credit (PTC) – A tax credit for certain people who enroll in a qualified health plan offered through the \nMarketplace (Exchange). The credit reduces the amount of tax the taxpayer owes. It may also give the taxpayer a \nrefund or increase the refund. \nIf applicable, the taxpayer is allowed a credit amount for any month during the year that the taxpayer or one or more \nof the taxpayer’s family members [spouse or dependent(s)] were:\n\t\n●Enrolled in one or more qualified health plans through a Marketplace;\n\t\n●Not eligible for other minimum essential coverage.\nQualified health plan – A health plan certified by the Department of Health and Human Services to be offered \nthrough the Marketplace. Qualified health plans offered through the Marketplace must be one of four tiers, or “metal \nlevels” – bronze, silver, gold, or platinum. Individuals and families can choose from a variety of qualified health plans, \nas well as catastrophic plans for young adults and those without affordable options. \nRecognized religious sect – For purposes of the individual shared responsibility provision, a religious sect that \nhas been in existence since December 31, 1950, that is recognized by the Social Security Administration (SSA) as \nconscientiously opposed to accepting any insurance benefits, including Medicare and social security. Members of a \nrecognized religious sect qualify for a coverage exemption.\nRequired contribution (for purposes of the premium tax credit) – If an individual is eligible for minimum essential \ncoverage through an employer, the required contribution is the portion of the annual premium that the individual \nwould pay for self-only coverage. \nRequired contribution (for purposes of the unaffordable coverage exemption) – If an individual is eligible for \nemployer coverage, the required contribution is the portion of the annual premium that the individual would pay for \nself-only coverage. If an individual’s family member is eligible for coverage through the individual’s employer, the \nrequired contribution for any member of the family is the portion of the annual premium that the individual must pay \nfor the lowest cost coverage that would cover everyone in the family who is not otherwise exempt from the individual \nshared responsibility provision. For individuals not eligible for employer coverage, the required contribution is the \nannual premium for the lowest cost bronze plan available in the individual market through the Marketplace in the \nstate in which the individual resides, reduced by the amount of the premium tax credit that would have been allowed \nif the individual had enrolled in a qualified health plan.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n20\nSecond Lowest Cost Silver Plan (SLCSP) – The second lowest cost silver plan offered through the Marketplace \nfor the rating area in which the taxpayer resides. A taxpayer who enrolled in a qualified health plan through the \nMarketplace will receive Form 1095-A, Health Insurance Marketplace Statement, from the Marketplace which will \ninclude the monthly premiums for the SLCSP\n. This figure is used on Form 8962, Premium Tax Credit, to calculate the \namount of the premium tax credit that the taxpayer is allowed. \nSelf-only coverage – (for the purpose of determining if coverage is unaffordable in order to claim a coverage \nexemption) – If a member of a tax household is eligible for self-only coverage under his or her employer’s plan, the \nrequired contribution amount is the amount the individual would pay (whether through salary reduction or otherwise) \nfor the lowest cost self-only coverage.\nShared responsibility payment (SRP) – If the taxpayer or any other member of the tax household did not have \neither minimum essential coverage or an exemption for any month during the tax year, the taxpayerwill owe a shared \nresponsibility payment. For 2019 and subsequent tax years, the SRP is zero.\nSpousal abandonment – A taxpayer is a victim of spousal abandonment for a taxable year if, taking into account all \nfacts and circumstances, the taxpayer is unable to locate his or her spouse after reasonable diligence.\nTax household (for purposes of the individual shared responsibility provision) – Tax household includes the \ntaxpayer, the taxpayer’s spouse (if filing a joint return), and any individual claimed as a dependent on the tax return. It \nalso includes each person the taxpayer can, but does not, claim as a dependent. \nUnaffordable coverage (for purposes of the premium tax credit) – Coverage is considered unaffordable if the \nindividual’s required contribution (see definition above) for employer-sponsored coverage is more than a certain \npercentage of household income. If employer coverage is considered unaffordable for an individual, the individual \nmay qualify to claim the premium tax credit if other requirements are met.\n", "AFFORDABALE CARE ACT: WHAT YOU AND YOUR FAMILY NEED TO KNOW\n21\n", "Publication 5187 (Rev. 2-2021) Catalog Number 67349C Department of the Treasury Internal Revenue Service IRS.gov\n" ]
n1444bes.pdf	0121 Notc 1444-B (EN-SP) (PDF)	https://www.irs.gov/pub/irs-pdf/n1444bes.pdf	[ "Notice 1444-B (en-sp) (1-2021) Catalog Number 74703A Department of the Treasury Internal Revenue Service www.irs.gov\nDepartment of the Treasury\nInternal Revenue Service\nAustin, TX 73301-0003\nNotice Date: \nNotice Number: 1444-B\nFor assistance, you may call:\n800-919-9835\nI Am Taxpayer \n123 Main Street\nOgden, UT 84401-2222\nYour Second Economic Impact Payment\nWhat you need to know\nThe U.S. Department of the Treasury issued you a second economic impact payment (EIP2) as provided by the COVID-\nrelated Tax Relief Act of 2020. \nAn EIP2 payment in the amount of [$XXXX.XX] was issued by [direct deposit or paper check/debit card]. \nYour EIP2 is based on information from your 2019 federal income tax return or information you provided using the Non-\nfilers tool. This information includes your filing status, the number of qualifying children, and your adjusted gross income. If \nyou didn’t provide information to the IRS but you are a federal benefit recipient, your EIP2 was sent to the bank account in \nwhich you receive benefits from the Social Security Administration (SSA), Railroad Retirement Board, or U.S. Department \nof Veterans Affairs (VA). \nYour EIP2 isn’t considered taxable income, and you shouldn’t report it as income on your 2020 federal income tax return. \nIf you receive federal benefits or federally financed benefits, those benefits generally won’t be affected by any EIP2 you \nreceive. \nYour EIP2 hasn’t been reduced for past due child support or any other federal or state debts.\nWhat you need to do\nIf you haven’t received your EIP2 within 7 days of receiving this letter, check the status by going to “Get My Payment” at \nIRS.gov/eip or by using the “Where’s My Economic Impact Payment” application on your smart device, or call 800-919-\n9835 for more information. \nIf you received your EIP2, you don’t need to call or take any action. If your circumstance has changed since filing your \n2019 return or receiving the first economic impact payment, you may request increases to the amount of your EIP2, (for \nreasons such as having a child in 2020) by claiming a recovery rebate credit on line 30 of your 2020 federal income tax \nreturn. \nYou should keep this letter and the letter you received with your earlier economic impact payment, if any, so that you \ncan refer to them when completing your 2020 federal income tax return. You can use the information in both letters to \ndetermine whether you should claim a recovery rebate credit on your 2020 return.\nThe IRS urges taxpayers to be on the lookout for scam artists trying to use the economic impact payments as cover for \nschemes to steal personal information and money. Remember, the IRS won’t call or otherwise contact you asking for \npersonal or bank account information – even related to the economic impact payments. Also, watch out for emails with \nattachments or links claiming to have special information about economic impact payments or refunds. \nFor more information about how your payment was calculated, please visit IRS.gov/coronavirus.\n", "Número del Aviso: 1444-B\nPara recibir asistencia, puede \nllamar al: 800-919-9835\nDepartment of the Treasury\nInternal Revenue Service\nAustin, TX 73301-0003\nFecha del Aviso:\nI Am Taxpayer \n123 Main Street\nOgden, UT 84401-2222\nSu segundo pago de alivio por el impacto económico\nLo que usted tiene que saber\nEl Departamento del Tesoro de los Estados Unidos le emitió un segundo pago de alivio por el impacto económico (EIP2, \npor sus siglas en inglés) conforme a la Ley de Alivio Tributario de 2020 relacionada con la COVID. \nSe emitió un pago de EIP2 por la cantidad de [$XXXX.XX] por [depósito directo o cheque en papel/tarjeta de débito]. \nSu EIP2 se basa en la información de su declaración de impuestos federales sobre los ingresos de 2019 o la información \nque usted proporcionó utilizando la herramienta Non-filers para las personas que no declaran. Esta información \nincluye su estado civil para efectos de la declaración, el número de hijos calificados y su ingreso bruto ajustado. Si no \nproporcionó información al IRS pero es un beneficiario de beneficios federales, su EIP2 se envió a la cuenta bancaria \nen la que usted recibe los beneficios de la Administración del Seguro Social (SSA, por sus siglas en inglés), Railroad \nRetirement Board (Junta de Jubilación Ferroviaria), o el Departamento de Asuntos de Veteranos de los Estados Unidos \n(VA, por sus siglas en inglés). \nSu EIP2 no se considera ingreso tributable y no tiene que declararlo como un ingreso en su declaración de impuestos \nfederales sobre los ingresos de 2020. Si usted recibe beneficios federales o beneficios financiados por el gobierno \nfederal, esos beneficios generalmente no se verán afectados por ningún EIP2 que usted reciba. \nSu EIP2 no se ha reducido por pagos atrasados de la manutención de hijos menores o por cualquier otra deuda federal o \nestatal. \nLo que usted tiene que hacer\nSi no ha recibido su EIP2 dentro de 7 días después de recibir esta carta, verifique el estado de su pago visitando \n“Obtener mi pago” en IRS.gov/es/eip, o utilizando la aplicación “¿Dónde está mi pago de alivio por el impacto \neconómico?” en su dispositivo inteligente, o llame al 800-919-9835 para obtener más información. \nSi recibió su EIP2, no tiene que llamar ni tomar ninguna acción. Si sus circunstancias han cambiado desde que presentó \nsu declaración de 2019 o recibió el primer pago de alivio por el impacto económico, puede solicitar aumentos a la \ncantidad de su EIP2 (por razones tales como tener un hijo en 2020) reclamando un crédito de recuperación de reembolso \nen la línea 30 de su declaración de impuestos federales sobre los ingresos de 2020. \nDebe guardar esta carta y la carta que recibió con su pago de alivio por el impacto económico anterior, si la hubiera, de \nmanera que pueda consultarlas al completar su declaración de impuestos federales sobre los ingresos de 2020. Puede \nutilizar la información de ambas cartas para determinar si debe reclamar un crédito de recuperación de reembolso en su \ndeclaración de 2020. \nEl IRS recomienda a los contribuyentes estar alerta a los estafadores que tratan de utilizar los pagos de alivio por \nel impacto económico como cobertura de sus planes para robar la información personal y dinero. Recuerde, el IRS \nno le llamará ni se comunicará con usted para solicitarle información personal o de cuenta bancaria, incluso \nrelacionada con los pagos de alivio por el impacto económico. Además, tenga cuidado con los correos electrónicos con \narchivos adjuntos o enlaces que afirman tener información especial sobre los pagos de alivio por el impacto económico o \nreembolsos. \nPara obtener más información sobre cómo se calculó su pago, por favor, visite IRS.gov/es/coronavirus.\nNotice 1444-B (en-sp) (1-2021) Catalog Number 74703A Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
p583.pdf	0121 Publ 583 (PDF)	https://www.irs.gov/pub/irs-pdf/p583.pdf	[ "Department of the Treasury\nInternal Revenue Service\nPublication 583\n(Rev. January 2021)\nCat. No. 15150B\nStarting a\nBusiness and\nKeeping \nRecords\nGet forms and other information faster and easier at:\n• IRS.gov (English) \n• IRS.gov/Spanish (Español) \n• IRS.gov/Chinese (中文) \n• IRS.gov/Korean (한국어) \n• IRS.gov/Russian (Pусский) \n• IRS.gov/Vietnamese (TiếngViệt) \nContents\nFuture Developments . . . . . . . . . . . . . . . . . . . . . . . 1\nIntroduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1\nWhat New Business Owners Need To Know\n. . . . . 2\nDetermining Which Type of Business to Use . . . . . 2\nGetting a Taxpayer Identification Number . . . . . . . 3\nEmployer Identification Number (EIN) . . . . . . . . . . 4\nPayee's Identification Number . . . . . . . . . . . . . . . 4\nDesignating a Tax Year\n. . . . . . . . . . . . . . . . . . . . . 4\nChoosing an Accounting Method . . . . . . . . . . . . . . 5\nBusiness Taxes\n. . . . . . . . . . . . . . . . . . . . . . . . . . . 5\nIncome Tax\n. . . . . . . . . . . . . . . . . . . . . . . . . . . . 5\nSelf-Employment Tax\n. . . . . . . . . . . . . . . . . . . . . 6\nEmployment Taxes . . . . . . . . . . . . . . . . . . . . . . . 7\nExcise Taxes . . . . . . . . . . . . . . . . . . . . . . . . . . . 8\nDepositing Taxes\n. . . . . . . . . . . . . . . . . . . . . . . . 8\nInformation Returns . . . . . . . . . . . . . . . . . . . . . . . . 8\nPenalties\n. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9\nDeducting Business Expenses\n. . . . . . . . . . . . . . . 9\nBusiness Start-Up Costs . . . . . . . . . . . . . . . . . . . 9\nDepreciation\n. . . . . . . . . . . . . . . . . . . . . . . . . . 10\nBusiness Use of Your Home\n. . . . . . . . . . . . . . . 10\nRecordkeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . 11\nHow To Get Tax Help\n. . . . . . . . . . . . . . . . . . . . . . 24\nIndex\n. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28\nFuture Developments\nFor the latest information about developments related to \nPub. 583, such as legislation enacted after it was \npublished, go to IRS.gov/Pub583.\nIntroduction\nThis publication provides basic federal tax information for \npeople who are starting a business. It also provides infor-\nmation on keeping records and illustrates a recordkeeping \nsystem.\nThroughout this publication we refer to other IRS publi-\ncations and forms where you will find more information. In \naddition, you may want to contact other government agen-\ncies, such as the Small Business Administration (SBA) at \nSBA.gov.\nComments and suggestions. We welcome your com-\nments about this publication and suggestions for future \neditions.\nFeb 03, 2021\n", "You can send us comments through IRS.gov/\nFormComments. Or, you can write to the Internal Reve-\nnue Service, Tax Forms and Publications, 1111 Constitu-\ntion Ave. NW, IR-6526, Washington, DC 20224.\nAlthough we can’t respond individually to each com-\nment received, we do appreciate your feedback and will \nconsider your comments and suggestions as we revise \nour tax forms, instructions, and publications. Do not send \ntax questions, tax returns, or payments to the above ad-\ndress.\nGetting answers to your tax questions. If you have \na tax question not answered by this publication or the How \nTo Get Tax Help section at the end of this publication, go \nto the IRS Interactive Tax Assistant page at IRS.gov/\nHelp/ITA where you can find topics by using the search \nfeature or viewing the categories listed.\nGetting tax forms, instructions, and publications. \nVisit IRS.gov/Forms to download current and prior-year \nforms, instructions, and publications.\nOrdering tax forms, instructions, and publications. \nGo to IRS.gov/OrderForms to order current forms, instruc-\ntions, and publications; call 800-829-3676 to order \nprior-year forms and instructions. The IRS will process \nyour order for forms and publications as soon as possible. \nDo not resubmit requests you’ve already sent us. You can \nget forms and publications faster online.\nWhat New Business Owners \nNeed To Know\nAs a new business owner, you need to know your federal \ntax responsibilities. Table 1 can help you learn what those \nresponsibilities are. Ask yourself each question listed in \nthe table, then see the related discussion to find the an-\nswer.\nIn addition to knowing about federal taxes, you need to \nmake some basic business decisions. Ask yourself:\n• What are my financial resources?\n• What products and services will I sell?\n• How will I market my products and services?\n• How will I develop a strategic business plan?\n• How will I manage my business on a day-to-day ba-\nsis?\n• How will I recruit employees?\nThe Small Business Administration (SBA) is a federal \nagency that can help you answer these types of ques-\ntions. For information about the SBA, see SBA.gov.\nDetermining Which Type of \nBusiness to Use\nThe most common forms of business are the sole proprie-\ntorship, partnership, and corporation. When beginning a \nbusiness, you must decide which form of business to use. \nTable 1. What New Business Owners Need To Know About Federal Taxes\n(Note: This table is intended to help you, as a new business owner, learn what you need to know about \nyour federal tax responsibilities. To use it, ask yourself each question in the left column, then see the \nrelated discussion in the right column.)\nWhat must I know?\nWhere to find the answer...\nWhich form of business will I use?\nSee Determining Which Type of Business to Use.\nWill I need an employer identification number (EIN)?\nSee Getting a Taxpayer Identification Number.\nDo I have to start my tax year in January, or may I start it in \nany other month?\nSee Designating a Tax Year.\nWhat method can I use to account for my income and \nexpenses?\nSee Choosing an Accounting Method.\nWhat kinds of federal taxes will I have to pay? How should I \npay my taxes?\nSee Business Taxes.\nWhat must I do if I have employees?\nSee Employment Taxes.\nWhich forms must I file?\nSee Table 2 and Information Returns.\nAre there penalties if I do not pay my taxes or file my returns?\nSee Penalties.\nWhat business expenses can I deduct on my federal income \ntax return?\nSee Deducting Business Expenses.\nWhat records must I keep? How long must I keep them?\nSee Recordkeeping.\nPage 2 \nPublication 583 (January 2021)\n", "Legal and tax considerations enter into this decision. Only \ntax considerations are discussed in this Pub. .\nYour form of business determines which income \ntax return form you have to file. See Table 2 to \nfind out which form you have to file.\nSole proprietorships. A sole proprietorship is an unin-\ncorporated business that is owned by one individual. It is \nthe simplest form of business organization to start and \nmaintain. The business has no existence apart from you, \nthe owner. Its liabilities are your personal liabilities. You \nundertake the risks of the business for all assets owned, \nwhether or not used in the business. You include the in-\ncome and expenses of the business on your personal tax \nreturn.\nMore information. For more information on sole pro-\nprietorships, see Pub. 334, Tax Guide for Small Business \n(For Individuals Who Use Schedule C). If you are a \nfarmer, see Pub. 225, Farmer's Tax Guide.\nPartnerships. A partnership is the relationship existing \nbetween two or more persons who join to carry on a trade \nor business. Each person contributes money, property, la-\nbor, or skill, and expects to share in the profits and losses \nof the business.\nA partnership must file an annual information return to \nreport the income, deductions, gains, losses, etc., from its \noperations, but it does not pay income tax. Instead, it \n“passes through” any profits or losses to its partners. Each \npartner includes his or her share of the partnership's items \non his or her tax return.\nMore information. For more information on partner-\nships, see Pub. 541, Partnerships.\nBusiness owned and operated by spouses. If you and \nyour spouse jointly own and operate an unincorporated \nbusiness and share in the profits and losses, you are part-\nners in a partnership, whether or not you have a formal \npartnership agreement. Do not use Schedule C. Instead, \nfile Form 1065, U.S. Return of Partnership Income. For \nmore information, see Pub. 541, Partnerships.\nException—Community Income. If you and your \nspouse wholly own an unincorporated business as com-\nmunity property under the community property laws of a \nstate, foreign country, or U.S. possession, you can treat \nthe business either as a sole proprietorship or a partner-\nship. States with community property laws include Ari-\nzona, California, Idaho, Louisiana, Nevada, New Mexico, \nTexas, Washington, and Wisconsin. See Pub. 555 for \nmore information about community property laws.\nException—Qualified joint venture. If you and your \nspouse each materially participate as the only members of \nan unincorporated, jointly owned and operated business, \nand you file a joint return for the tax year, you can make a \njoint election to be treated as a qualified joint venture in-\nstead of a partnership for the tax year. Making this elec-\ntion will allow you to avoid the complexity of Form 1065 \nbut still give each spouse credit for social security earn-\nings on which retirement benefits are based. For an \nTIP\nexplanation of \"material participation,\" see the instructions \nfor Schedule C, line G.\nTo make this election, you must divide all items of in-\ncome, gain, loss, deduction, and credit attributable to the \nbusiness between you and your spouse in accordance \nwith your respective interests in the venture. Each of you \nmust file a separate Schedule C and a separate Sched-\nule SE. For more information, see Qualified Joint Venture \nin the Instructions for Schedule SE.\nCorporations. In forming a corporation, prospective \nshareholders exchange money, property, or both, for the \ncorporation's capital stock. A corporation generally takes \nthe same deductions as a sole proprietorship to figure its \ntaxable income. A corporation can also take special de-\nductions.\nC corporations. The profit of a C corporation is taxed \nto the corporation when earned, and then is taxed to the \nshareholders when distributed as dividends. However, \nshareholders cannot deduct any loss of the corporation. \nFor more information on corporations, see Pub. 542, Cor-\nporations.\nS corporations. An eligible domestic corporation (or a \ndomestic entity eligible to elect to be treated as a corpora-\ntion) can avoid double taxation (once to the corporation \nand again to the shareholders) as long as it meets certain \ntests and elects to be treated as an S corporation. Gener-\nally, an S corporation is exempt from federal income tax \nother than tax on certain capital gains and passive in-\ncome. On their tax returns, the S corporation's sharehold-\ners include their share of the corporation's separately sta-\nted items of income, deduction, loss, and credit, and their \nshare of nonseparately stated income or loss. For more \ninformation on S corporations and the tests that need to \nbe met to be eligible to elect to be an S corporation, see \nthe instructions for Form 2553, Election by a Small Busi-\nness Corporation, and Form 1120-S, U.S. Income Tax Re-\nturn for an S Corporation.\nLimited liability company. A limited liability company \n(LLC) is an entity formed under state law by filing articles \nof organization as an LLC. The members of an LLC are \nnot personally liable for its debts. An LLC may be classi-\nfied for federal income tax purposes as either a partner-\nship, a corporation, or an entity disregarded as separate \nfrom its owner by applying the rules in Regulations section \n301.7701-3.\nMore information. For more information on LLCs, see \nthe Instructions for Form 8832, Entity Classification Elec-\ntion.\nGetting a Taxpayer \nIdentification Number\nYou must have a taxpayer identification number so the \nIRS can process your returns. Two of the most common \nPublication 583 (January 2021)\n Page 3\n", "kinds of taxpayer identification numbers are the social se-\ncurity number (SSN) and the employer identification num-\nber (EIN).\n• An SSN is issued to individuals by the Social Security \nAdministration (SSA) and is in the following format: \n000–00–0000.\n• An EIN is issued to individuals (sole proprietors), part-\nnerships, corporations, and other entities by the IRS \nand is in the following format: 00–0000000.\nProviding your identification number to others. You \nmust include your taxpayer identification number (SSN or \nEIN) on all returns and other documents you send to the \nIRS. You must also give your number to other persons \nwho use your identification number on any returns or \ndocuments they send to the IRS. This includes returns or \ndocuments filed to report the following information.\n1. Interest, dividends, royalties, etc., paid to you.\n2. Any amount paid to you as a dependent care pro-\nvider.\n3. Certain other amounts paid to you that total $600 or \nmore for the year.\nIf you do not furnish your identification number as re-\nquired, you may be subject to penalties. See Penalties, \nlater.\nEmployer Identification Number (EIN)\nEINs are assigned to sole proprietors, LLCs, corporations, \nand partnerships for tax filing and reporting purposes. See \nForm SS-4 and its instructions for more information and to \nsee which businesses must get an EIN.\nApplying for an EIN. You may apply for an EIN:\n• Online—Click on the Employer ID Numbers (EINs) link \nat IRS.gov/businesses/small. The EIN is issued imme-\ndiately once the application information is validated.\n• By mailing or faxing Form SS-4, Application for Em-\nployer Identification Number.\n• International applicants may call 267-941-1099 (not a \ntoll-free number).\nWhen to apply. You should apply for an EIN early \nenough to receive the number by the time you must file a \nreturn or statement or make a tax deposit. If you apply by \nmail, file Form SS-4 at least 4 weeks before you need an \nEIN. If you apply by telephone or through the IRS website, \nyou can get an EIN immediately. If you apply by fax, you \ncan get an EIN within 4 business days.\nIf you do not receive your EIN by the time a return is \ndue, file your return anyway. Write “Applied for” and the \ndate you applied for the number in the space for the EIN. \nDo not use your social security number as a substitute for \nan EIN on your tax returns.\nMore than one EIN. You should have only one EIN for a \nbusiness entity. If you have more than one EIN and are \nnot sure which to use, contact the Internal Revenue Serv-\nice Center where you file your return. Give the numbers \nyou have, the name and address to which each was as-\nsigned, and the address of your main place of business. \nThe IRS will tell you which number to use.\nMore information. For more information about EINs, see \nPub. 1635, Understanding Your EIN.\nPayee's Identification Number\nIn the operation of a business, you will probably make cer-\ntain payments you must report on information returns (dis-\ncussed later under Information Returns). The forms used \nto report these payments must include the payee's identi-\nfication number.\nEmployee. If you have employees, you must get an SSN \nfrom each of them. Record the name and SSN of each \nemployee exactly as they are shown on the employee's \nsocial security card. If the employee's name is not correct \nas shown on the card, the employee should request a new \ncard from the SSA. This may occur, for example, if the \nemployee's name has changed due to marriage or di-\nvorce.\nIf your employee does not have an SSN, he or she \nshould file Form SS-5, Application for a Social Security \nCard, with the SSA. This form is available at SSA offices \nor by calling 800-772-1213. It is also available from the \nSSA website at SSA.gov.\nOther payee. If you make payments to someone who is \nnot your employee and you must report the payments on \nan information return, get that person's SSN. If you make \nreportable payments to an organization, such as a corpo-\nration or partnership, you must get its EIN.\nTo get the payee's SSN or EIN, use Form W-9, Re-\nquest for Taxpayer Identification Number and Certifica-\ntion. For more information, see IRS.gov/FormW9.\nIf the payee does not provide you with an identifi-\ncation number, you may have to withhold part of \nthe payments as backup withholding. For informa-\ntion on backup withholding, see the Instructions for the \nRequester of Form W-9 and the General Instructions for \nCertain Information Returns.\nDesignating a Tax Year\nYou must figure your taxable income and file an income \ntax return based on an annual accounting period called a \ntax year. A tax year is usually 12 consecutive months. \nThere are two kinds of tax years.\n1. Calendar tax year. A calendar tax year is 12 consec-\nutive months beginning January 1 and ending De-\ncember 31.\n2. Fiscal tax year. A fiscal tax year is 12 consecutive \nmonths ending on the last day of any month except \nDecember. A 52-53-week tax year is a fiscal tax year \nCAUTION\n!\nPage 4 \nPublication 583 (January 2021)\n", "that varies from 52 to 53 weeks but does not have to \nend on the last day of a month.\nIf you file your first tax return using the calendar tax \nyear and you later begin business as a sole proprietor, be-\ncome a partner in a partnership, or become a shareholder \nin an S corporation, you must continue to use the calendar \nyear unless you get IRS approval to change it or are other-\nwise allowed to change it without IRS approval.\nYou must use a calendar tax year if:\n• You keep no books or records.\n• You have no annual accounting period.\n• Your present tax year does not qualify as a fiscal year.\n• You are required to use a calendar year by a provision \nof the Internal Revenue Code or the Income Tax Reg-\nulations.\nFor more information, see Pub. 538, Accounting Peri-\nods and Methods.\nFirst-time filer. If you have never filed an income tax re-\nturn for your business, you can adopt either a calendar tax \nyear or a fiscal tax year. Although, some partnerships and \nS corporations must use a particular tax year. See Pub. \n538 for more information.\nYou adopt a tax year by filing your first income tax re-\nturn using that tax year. You have not adopted a tax year if \nall you did was one or more of the following.\n• Filed an application for an extension of time to file an \nincome tax return.\n• Filed an application for an employer identification \nnumber.\n• Paid estimated taxes for that tax year.\nChanging your tax year. Once you have adopted your \ntax year, you may have to get IRS approval to change it. \nTo get approval, you must file Form 1128, Application To \nAdopt, Change, or Retain a Tax Year. You may have to \npay a fee. For more information, see Pub. 538.\nChoosing an Accounting \nMethod\nAn accounting method is a set of rules used to determine \nwhen and how income and expenses are reported. You \nchoose an accounting method for your business when you \nfile your first income tax return. There are two basic ac-\ncounting methods.\n1. Cash method. Under the cash method, you report in-\ncome in the tax year you receive it. You usually de-\nduct or capitalize expenses in the tax year you pay \nthem.\n2. Accrual method. Under an accrual method, you gen-\nerally report income in the tax year you earn it, even \nthough you may receive payment in a later year. You \ndeduct or capitalize expenses in the tax year you \nincur them, whether or not you pay them that year.\nFor other methods, see Pub. 538.\nIf an inventory is necessary to account for your income, \nyou must generally use an accrual method of accounting \nfor purchases and sales. Inventories include goods held \nfor sale in the normal course of business. They also in-\nclude raw materials and supplies that will physically be-\ncome a part of merchandise intended for sale. Inventories \nare explained in Pub. 538.\nCertain small business taxpayers can use the \ncash method of accounting and can also account \nfor inventoriable items as materials and supplies \nthat are not incidental. For more information, see Pub. \n538.\nYou must use the same accounting method to figure \nyour taxable income and to keep your books. Also, you \nmust use an accounting method that clearly shows your \nincome. In general, any accounting method that consis-\ntently uses accounting principles suitable for your trade or \nbusiness clearly shows income. An accounting method \nclearly shows income only if it treats all items of gross in-\ncome and expense the same from year to year.\nMore than one business. When you own more than one \nbusiness, you can use a different accounting method for \neach business if the method you use for each clearly \nshows your income. You must keep a complete and sepa-\nrate set of books and records for each business.\nChanging your method of accounting. Once you have \nset up your accounting method, you must generally get \nIRS approval before you can change to another method. A \nchange in accounting method not only includes a change \nin your overall system of accounting, but also a change in \nthe treatment of any material item. For examples of \nchanges that require approval and information on how to \nget approval for the change, see Pub. 538.\nBusiness Taxes\nThe form of business you operate determines what taxes \nyou must pay and how you pay them. The following are \nthe four general kinds of business taxes.\n• Income tax.\n• Self-employment tax.\n• Employment taxes.\n• Excise taxes.\nSee Table 2 for the forms you file to report these taxes.\nYou may want to get Pub. 509. It has tax calen-\ndars that tell you when to file returns and make \ntax payments.\nIncome Tax\nAll businesses except partnerships must file an annual in-\ncome tax return. Partnerships file an information return. \nTIP\nTIP\nPublication 583 (January 2021)\n Page 5\n", "Which form you use depends on how your business is or-\nganized. See Table 2 to find out which return you have to \nfile.\nThe federal income tax is a pay-as-you-go tax. You \nmust pay the tax as you earn or receive income during the \nyear. An employee usually has income tax withheld from \nhis or her pay. If you do not pay your tax through withhold-\ning, or do not pay enough tax that way, you might have to \npay estimated tax. If you are not required to make estima-\nted tax payments, you may pay any tax due when you file \nyour return.\nReminder. If your business is an LLC, how you elected to \nhave the LLC treated for tax purposes (either as a corpo-\nration, partnership, or as part of the LLC owner's tax re-\nturn) will determine what taxes you must pay and what \nforms you should use to pay your taxes.\nEstimated tax. Generally, you must pay taxes on in-\ncome, including self-employment tax (discussed next), by \nmaking regular payments of estimated tax during the year.\nSole proprietors, partners, and S corporation \nshareholders. You generally have to make estimated tax \npayments if you expect to owe tax of $1,000 or more \nwhen you file your return. Use Form 1040-ES, Estimated \nTax for Individuals, to figure and pay your estimated tax. \nFor more information, see Pub. 505, Tax Withholding and \nEstimated Tax.\nCorporations. You generally have to make estimated \ntax payments for your corporation if you expect it to owe \ntax of $500 or more when you file its return. Use Form \n1120-W, Estimated Tax for Corporations, to figure the es-\ntimated tax. You must deposit the payments as explained \nlater under Depositing Taxes. For more information, see \nPub. 542.\nSelf-Employment Tax\nSelf-employment tax (SE tax) is a social security and \nMedicare tax primarily for individuals who work for them-\nselves. Your payments of SE tax contribute to your cover-\nage under the social security system. Social security \nTable 2. Which Forms Must I File?\nIF you are a...\nTHEN you may have to pay...\nFILE form...\nSole proprietor\nIncome tax\n1040 or 1040-SR, and Schedule C 1 \n(Schedule F 1 for farm business)\nSelf-employment tax\n1040 or 1040-SR, and Schedule SE\nEstimated tax\n1040-ES\nEmployment taxes:\n • Social security and Medicare \n taxes and income tax \n withholding\n941 or 944 (943 for farm employees)\n • Federal unemployment (FUTA) \n tax\n940 \nExcise taxes\nSee Excise Taxes\nPartnership\nAnnual return of income\n1065\nEmployment taxes\nSame as sole proprietor\nExcise taxes\nSee Excise Taxes\nPartner in a partnership (individual)\nIncome tax\n1040 or 1040-SR, and Schedule E 2\nSelf-employment tax\n1040 or 1040-SR, and Schedule SE\nEstimated tax\n1040-ES\nC corporation or S corporation\nIncome tax\n1120 (C corporation) 2\n1120-S (S corporation) 2\nEstimated tax\n1120-W (corporation only)\nEmployment taxes\nSame as sole proprietor\nExcise taxes\nSee Excise Taxes\nS corporation shareholder\nIncome tax\n1040 or 1040-SR, and Schedule E 2\nEstimated tax\n1040-ES\n1 File a separate schedule for each business.\n2 Various other schedules may be needed.\nPage 6 \nPublication 583 (January 2021)\n", "coverage provides you with retirement benefits, disability \nbenefits, survivor benefits, and hospital insurance (Medi-\ncare) benefits.\nYou must pay SE tax and file Schedule SE (Form 1040) \nif either of the following applies.\n1. Your net earnings from self-employment were $400 or \nmore.\n2. You had church employee income of $108.28 or \nmore.\nUse Schedule SE (Form 1040) to figure your SE tax. For \nmore information, see Pub. 334.\nYou can deduct a portion of your SE tax as an ad-\njustment to income on your Form 1040 or \n1040-SR.\nThe Social Security Administration (SSA) time limit \nfor posting self-employment income. Generally, the \nSSA will give you credit only for self-employment income \nreported on a tax return filed within 3 years, 3 months, and \n15 days after the tax year you earned the income. If you \nfile your tax return or report a change in your self-employ-\nment income after this time limit, the SSA may change its \nrecords, but only to remove or reduce the amount. The \nSSA will not change its records to increase your self-em-\nployment income.\nEmployment Taxes\nThis section briefly discusses the employment taxes you \nmust pay, the forms you must file to report them, and \nother forms that must be filed when you have employees.\nEmployment taxes include the following.\n• Social security and Medicare taxes.\n• Federal income tax withholding.\n• Federal unemployment (FUTA) tax.\nIf you have employees, you will need to get Pub. 15 \n(Circular E), Employer's Tax Guide. If you have agricul-\ntural employees, get Pub. 51 (Circular A), Agricultural Em-\nployer's Tax Guide. These publications explain your tax \nresponsibilities as an employer.\nIf you are not sure whether the people working for you \nare your employees, see Pub. 15-A, Employer's Supple-\nmental Tax Guide. That publication has information to \nhelp you determine whether an individual is an employee \nor an independent contractor. Also, people who provide a \nservice generally associated with the sharing (or on-de-\nmand, gig, or access) economy are, under certain circum-\nstances, independent contractors. An independent con-\ntractor is someone who is self-employed. Generally, you \ndo not have to withhold or pay any taxes on payments to \nan independent contractor. If you wrongly classify an em-\nployee as an independent contractor, you can be held lia-\nble for employment taxes for that worker plus a penalty.\nTIP\nFederal Income, Social Security, and \nMedicare Taxes\nYou generally must withhold federal income tax from your \nemployee's wages. To figure how much federal income \ntax to withhold from each wage payment, use the employ-\nee's Form W-4 (discussed later under Hiring Employees) \nand the methods described in Publication 15-T, Federal \nIncome Tax Withholding Methods. Pub. 15-T provides in-\nstructions about how to apply Form W-4 to calculate with-\nholding on the employee.\nSocial security and Medicare taxes pay for benefits that \nworkers and their families receive under the Federal Insur-\nance Contributions Act (FICA). Social security tax pays for \nbenefits under the old-age, survivors, and disability insur-\nance part of FICA. Medicare tax pays for benefits under \nthe hospital insurance part of FICA. You withhold part of \nthese taxes from your employee's wages and you pay a \npart yourself. To find out how much social security and \nMedicare tax to withhold and to pay, see Pub. 15.\nWhich form do I file? Report these taxes on Form 941, \nEmployer's QUARTERLY Federal Tax Return, or Form \n944, Employer's ANNUAL Federal Tax Return. (Farm em-\nployers use Form 943, Employer's Annual Federal Tax \nReturn for Agricultural Employees.)\nFederal Unemployment (FUTA) Tax\nThe federal unemployment tax is part of the federal and \nstate program under the Federal Unemployment Tax Act \n(FUTA) that pays unemployment compensation to work-\ners who lose their jobs. You report and pay FUTA tax sep-\narately from social security and Medicare taxes and with-\nheld income tax. You pay FUTA tax only from your own \nfunds. Employees do not pay this tax or have it withheld \nfrom their pay.\nWhich form do I file? Report federal unemployment tax \non Form 940, Employer's Annual Federal Unemployment \n(FUTA) Tax Return. See Pub. 15 to find out if you can use \nthis form.\nHiring Employees\nHave the employees you hire fill out Form I-9 and Form \nW-4.\nForm I-9. You must verify that each new employee is le-\ngally eligible to work in the United States. Both you and \nthe employee must complete the U.S. Citizenship and Im-\nmigration Services (USCIS) Form I-9, Employment Eligi-\nbility Verification. You can get the form from USCIS offices \nor from the USCIS website at USCIS.gov. Call the USCIS \nat 800-375-5283 for more information about your respon-\nsibilities.\nForm W-4. Each employee must fill out Form W-4, Em-\nployee's Withholding Certificate. You will use the informa-\ntion provided on this form to figure the amount of income \nPublication 583 (January 2021)\n Page 7\n", "tax to withhold from your employee's wages. For more in-\nformation, see Pub. 15-T.\nForm W-2 Wage Reporting\nAfter the calendar year is over, you must furnish copies of \nForm W-2, Wage and Tax Statement, to each employee \nto whom you paid wages during the year. You must also \nsend copies to the Social Security Administration. See In-\nformation Returns, later, for more information on Form \nW-2.\nExcise Taxes\nThis section describes the excise taxes you may have to \npay and the forms you have to file if you do any of the fol-\nlowing.\n• Manufacture or sell certain products.\n• Operate certain kinds of businesses.\n• Use various kinds of equipment, facilities, or products.\n• Receive payment for certain services.\nFor more information on excise taxes, see Pub. 510, Ex-\ncise Taxes.\nForm 720. The federal excise taxes reported on Form \n720, Quarterly Federal Excise Tax Return, consist of sev-\neral broad categories of taxes, including the following.\n• Environmental taxes.\n• Communications and air transportation taxes.\n• Fuel taxes.\n• Tax on the first retail sale of heavy trucks, trailers, and \ntractors.\n• Manufacturers taxes on the sale or use of a variety of \ndifferent articles.\nForm 2290. There is a federal excise tax on certain \ntrucks, truck tractors, and buses used on public highways. \nThe tax applies to vehicles having a taxable gross weight \nof 55,000 pounds or more. Report the tax on Form 2290, \nHeavy Highway Vehicle Use Tax Return. For more infor-\nmation, see the Instructions for Form 2290.\nForm 730. If you are in the business of accepting wagers \nor conducting a wagering pool or lottery, you may be liable \nfor the federal excise tax on wagering. Use Form 730, \nMonthly Tax Return for Wagers, to figure the tax on the \nwagers you receive.\nForm 11-C. Use Form 11-C, Occupational Tax and Reg-\nistration Return for Wagering, to register for any wagering \nactivity and to pay the federal occupational tax on wager-\ning.\nDepositing Taxes\nYou generally have to deposit federal employment taxes, \ncertain excise taxes, corporate income tax, and S \ncorporation taxes before you file your return.\nYou must use an electronic funds transfer (EFT) to \nmake all federal tax deposits. Generally, an EFT is made \nusing the Electronic Federal Tax Payment System \n(EFTPS). If you don't want to use EFTPS, you can arrange \nfor your tax professional, financial institution, payroll serv-\nice, or other trusted third party to make electronic deposits \non your behalf.\nAny business that has a federal tax obligation and re-\nquests a new EIN will automatically be enrolled in EFTPS. \nThrough the mail, the business will receive an EFTPS PIN \npackage that contains instructions for activating its EFTPS \nenrollment.\nInformation Returns\nIf you make or receive payments in your business, you \nmay have to report them to the IRS on information returns. \nThe IRS compares the payments shown on the informa-\ntion returns with each person's income tax return to see if \nthe payments were included in income. You must give a \ncopy of each information return you are required to file to \nthe recipient or payer. In addition to the forms described \nbelow, you may have to use other returns to report certain \nkinds of payments or transactions. For more details on in-\nformation returns and when you have to file them, see the \nGeneral Instructions for Certain Information Returns.\nForm 1099-MISC. Use Form 1099-MISC, Miscellaneous \nIncome, to report certain payments you make in your \ntrade or business. These payments include the following \nitems.\n• Royalty payments of $10 or more.\n• Rent payments of $600 or more, other than rents paid \nto real estate agents.\n• Prizes and awards of $600 or more that are not for \nservices, such as winnings on TV or radio shows.\n• Payments to certain crew members by operators of \nfishing boats.\n• Cash payments of $600 or more for fish (or other \naquatic life) you purchase from anyone engaged in the \ntrade or business of catching fish.\nEither the Form 1099-MISC or Form 1099-NEC can be \nused to report sales totaling $5,000 or more of consumer \nproducts to a person on a buy-sell, deposit-commission, \nor other commission basis for resale anywhere other than \nin a permanent retail establishment. For more information \non what to report on Form 1099-MISC, see the Instruc-\ntions for Forms 1099-MISC and 1099-NEC.\nForm 1099-NEC. Use Form 1099-NEC, Nonemployee \nCompensation, to report certain payments you make in \nyour trade or business. These payments include the fol-\nlowing items.\n• Payments of $600 or more for services performed by \nsomeone who is not your employee.\nPage 8 \nPublication 583 (January 2021)\n", "• If you withheld certain federal income tax under the \nbackup withholding rules regardless of the amount of \nthe payment.\nYou may choose to report direct sales of $5,000 or more \nof consumer goods to a person for resale on Form \n1099-NEC rather than Form 1099-MISC. For more infor-\nmation on what to report on Form 1099-NEC, see the In-\nstructions for Forms 1099-MISC and 1099-NEC.\nForm W-2. You must file Form W-2, Wage and Tax \nStatement, to report payments to your employees, such \nas wages, tips, and other compensation, withheld income, \nsocial security, and Medicare taxes. For more information \non what to report on Form W-2, see the Instructions for \nForms W-2 and W-3.\nForm 8300. You must file Form 8300, Report of Cash \nPayments Over $10,000 Received in a Trade or Business, \nif you receive more than $10,000 in cash in one transac-\ntion or two or more related business transactions. Cash in-\ncludes U.S. and foreign coin and currency. It also includes \ncertain monetary instruments such as cashier's and travel-\ner's checks and money orders. For more information, see \nPub. 1544, Reporting Cash Payments of Over $10,000.\nPenalties\nThe law provides penalties for not filing returns or paying \ntaxes as required. Criminal penalties may be imposed for \nwillful failure to file, tax evasion, or making a false state-\nment.\nFailure to file tax returns. If you do not file your tax re-\nturn by the due date, you may have to pay a penalty. The \npenalty is based on the tax not paid by the due date. See \nyour tax return instructions for more information about this \npenalty.\nFailure to pay tax. If you do not pay your taxes by the \ndue date, you will have to pay a penalty for each month, or \npart of a month, that your taxes are not paid. For more in-\nformation, see your tax return instructions.\nFailure to withhold, deposit, or pay taxes. If you do \nnot withhold income, social security, or Medicare taxes \nfrom employees, or if you withhold taxes but do not de-\nposit them or pay them to the IRS, you may be subject to \na penalty of the unpaid tax, plus interest. You may also be \nsubject to penalties if you deposit the taxes late. For more \ninformation, see Pub. 15.\nFailure to follow information reporting requirements. \nThe following penalties apply if you are required to file in-\nformation returns. For more information, see the General \nInstructions for Certain Information Returns.\n• Failure to file information returns. A penalty ap-\nplies if you do not file information returns by the due \ndate, if you do not include all required information, or if \nyou report incorrect information.\n• Failure to furnish correct payee statements. A \npenalty applies if you do not furnish a required state-\nment to a payee by the due date, if you do not include \nall required information, or if you report incorrect infor-\nmation.\nWaiver of penalty. These penalties will not apply if \nyou can show that the failures were due to reasonable \ncause and not willful neglect.\nIn addition, there is no penalty for failure to include all \nthe required information, or for including incorrect informa-\ntion, on a de minimis number of information returns if you \ncorrect the errors by August 1 of the year the returns are \ndue. (To be considered de minimis, the number of returns \ncannot exceed the greater of 10 or 1/2 of 1% of the total \nnumber of returns you are required to file for the year.) \nThere is also no penalty, and no need for a corrected re-\nturn to be filed, for incorrect dollar amounts where no sin-\ngle amount differs from the correct amount by more than \n$100 ($25 for tax withheld).\nFailure to supply taxpayer identification number. If \nyou do not include your taxpayer identification number \n(SSN or EIN) or the taxpayer identification number of an-\nother person where required on a return, statement, or \nother document, you may be subject to a penalty of $50 \nfor each failure. You may also be subject to the $50 pen-\nalty if you do not give your taxpayer identification number \nto another person when it is required on a return, state-\nment, or other document.\nDeducting Business Expenses\nYou can deduct business expenses on your business or \npersonal income tax return, depending on the form of your \nbusiness. These are the current operating costs of running \nyour business. To be deductible, a business expense \nmust be both ordinary and necessary. An ordinary ex-\npense is one that is common and accepted in your field of \nbusiness, trade, or profession. A necessary expense is \none that is helpful and appropriate for your business, \ntrade, or profession. An expense does not have to be in-\ndispensable to be considered necessary.\nThe following are brief explanations of some expenses \nthat are of interest to people starting a business. There \nare many other expenses that you may be able to deduct. \nSee your form instructions and Pub. 535, Business Ex-\npenses.\nBusiness Start-Up Costs\nBusiness start-up costs are the expenses you incur before \nyou actually begin business operations. Your business \nstart-up costs will depend on the type of business you are \nstarting. They may include costs for advertising, travel, \nsurveys, and training. These costs are generally capital \nexpenses.\nYou usually recover costs for a particular asset (such \nas machinery or office equipment) through depreciation \n(discussed next). However, you can elect to deduct up to \nPublication 583 (January 2021)\n Page 9\n", "$10,000 of business start-up costs and up to $5,000 of or-\nganizational costs. The $10,000 deduction for business \nstart-up costs is reduced by the amount your total start-up \ncosts exceed $60,000. The $5,000 deduction for organi-\nzational costs is reduced by the amount your total organi-\nzational costs exceed $50,000. Any remaining costs must \nbe amortized.\nFor more information about amortizing start-up and or-\nganizational costs, see chapter 7 in Pub. 535.\nDepreciation\nIf property you acquire to use in your business has a use-\nful life that extends substantially beyond the year it is \nplaced in service, you generally cannot deduct the entire \ncost as a business expense in the year you acquire it. You \nmust spread the cost over more than one tax year and de-\nduct part of it each year. This method of deducting the \ncost of business property is called depreciation.\nBusiness property you must depreciate includes the \nfollowing items.\n• Office furniture.\n• Buildings.\n• Machinery and equipment.\nYou can choose to deduct a limited amount of the cost \nof certain depreciable property in the year you place the \nproperty in service. This deduction is known as the “sec-\ntion 179 deduction.” For more information about deprecia-\ntion and the section 179 deduction, see Pub. 946, How To \nDepreciate Property.\nDepreciation must be taken in the year it is allow-\nable. Allowable depreciation not taken in a prior \nyear cannot be taken in the current year. If you do \nnot deduct the correct depreciation, you may be able to \nmake a correction by filing Form 1040-X, Amended U.S. \nIndividual Income Tax Return, or by changing your ac-\ncounting method. For more information on how to correct \ndepreciation deductions, see chapter 1, How Do You Cor-\nrect Depreciation Deductions?, in Pub. 946.\nBusiness Use of Your Home\nTo deduct expenses related to the business use of your \nhome, you must meet specific requirements. However, \neven if you meet the requirements your deduction may still \nbe limited.\nTo qualify to claim expenses for business use of your \nhome, you must meet both the following tests.\n1. Your use of the business part of your home must be:\na. Exclusive (however, see Exceptions to exclusive \nuse, later),\nb. Regular,\nc. For your trade or business, AND\n2. The business part of your home must be one of the \nfollowing:\nTIP\na. Your principal place of business (defined later),\nb. A place where you meet or deal with patients, cli-\nents, or customers in the normal course of your \ntrade or business, or\nc. A separate structure (not attached to your home) \nyou use in connection with your trade or business.\nExclusive use. To qualify under the exclusive use test, \nyou must use a specific area of your home only for your \ntrade or business. The area used for business can be a \nroom or other separately identifiable space. The space \ndoes not need to be marked off by a permanent partition.\nYou do not meet the requirements of the exclusive use \ntest if you use the area in question both for business and \nfor personal purposes.\nExceptions to exclusive use. You do not have to meet \nthe exclusive use test if either of the following applies.\n1. You use part of your home for the storage of inventory \nor product samples.\n2. You use part of your home as a daycare facility.\nFor an explanation of these exceptions, see Pub. 587, \nBusiness Use of Your Home (Including Use by Daycare \nProviders).\nPrincipal place of business. Your home office will qual-\nify as your principal place of business for deducting ex-\npenses for its use if you meet the following requirements.\n• You use it exclusively and regularly for administrative \nor management activities of your trade or business.\n• You have no other fixed location where you conduct \nsubstantial administrative or management activities of \nyour trade or business.\nAlternatively, if you use your home exclusively and reg-\nularly for your business, but your home office does not \nqualify as your principal place of business based on the \nprevious rules, you determine your principal place of busi-\nness based on the following factors.\n• The relative importance of the activities performed at \neach location.\n• If the relative importance factor does not determine \nyour principal place of business, the time spent at \neach location.\nIf, after considering your business locations, your home \ncannot be identified as your principal place of business, \nyou cannot deduct home office expenses. However, for \nother ways to qualify to deduct home office expenses, see \nPub. 587.\nSimplified method. The simplified method is an alterna-\ntive to the calculation, allocation, and substantiation of ac-\ntual expenses normally required to determine your home \noffice expense deduction. With this method, you will gen-\nerally figure your deduction by multiplying $5, the prescri-\nbed rate, by the area of your home (measured in square \nfeet) used for a qualified business. The area you use to \nfigure your deduction is limited to 300 square feet. For \nPage 10 \nPublication 583 (January 2021)\n", "more information about the simplified method, see Reve-\nnue Procedure 2013-13, 2013-06 I.R.B. 478, available at \nIRS.gov/irb/2013-06_IRB#RP-2013-13.\nWhich form do I file? If you file Schedule C (Form \n1040), use Form 8829, Expenses for Business Use of \nYour Home. However, if you elect to use the simplified \nmethod, use the Simplified Method Worksheet in the In-\nstructions for Schedule C or Pub. 587.\nIf you file Schedule F (Form 1040) or are a partner, you \nshould use the Worksheet To Figure the Deduction for \nBusiness Use of Your Home in Pub. 587. However, if you \nelect to use the simplified method, use the Simplified \nMethod Worksheet in Pub. 587.\nMore information. For more information about business \nuse of your home, see Pub. 587.\nCar and Truck Expenses\nIf you use your car or truck in your business, you can de-\nduct the costs of operating and maintaining it. You gener-\nally can deduct either your actual expenses or the stand-\nard mileage rate.\nActual expenses. If you deduct actual expenses, you \ncan deduct the cost of the following items:\nDepreciation \nLease payments\nRegistration \nGarage rent\nLicenses\nRepairs \nGas\nOil\nTires \nInsurance\nParking fees\nTolls \nIf you use your vehicle for both business and personal \npurposes, you must divide your expenses between busi-\nness and personal use. You can divide your expenses \nbased on the miles driven for each purpose.\nExample. You are the sole proprietor of a flower shop. \nYou drove your van 20,000 miles during the year. 16,000 \nmiles were for delivering flowers to customers and 4,000 \nmiles were for personal use. You can claim only 80% \n(16,000 ÷ 20,000) of the cost of operating your van as a \nbusiness expense.\nStandard mileage rate. Instead of figuring actual expen-\nses, you may be able to use the standard mileage rate to \nfigure the deductible costs of operating your car, van, \npickup, or panel truck for business purposes. You can use \nthe standard mileage rate for a vehicle you own or lease. \nThe standard mileage rate is a specified amount of money \nyou can deduct for each business mile you drive. It is an-\nnounced annually by the IRS. To figure your deduction, \nmultiply your business miles by the standard mileage rate \nfor the year.\nGenerally, if you use the standard mileage rate, \nyou cannot deduct your actual expenses. How-\never, you may be able to deduct business-related \nparking fees, tolls, interest on your car loan, and certain \nstate and local taxes.\nCAUTION\n!\nChoosing the standard mileage rate. If you want to \nuse the standard mileage rate for a car you own, you must \nchoose to use it in the first year the car is available for use \nin your business. In later years, you can choose to use ei-\nther the standard mileage rate or actual expenses.\nIf you use the standard mileage rate for a car you lease, \nyou must choose to use it for the entire lease period (in-\ncluding renewals).\nAdditional information. For more information about the \nrules for claiming car and truck expenses, see Pub. 463, \nTravel, Entertainment, Gift, and Car Expenses.\nRecordkeeping\nThis part explains why you must keep records, what kinds \nof records you must keep, and how to keep them. It also \nexplains how long you must keep your records for federal \ntax purposes. A sample recordkeeping system is illustra-\nted at the end of this part.\nWhy Keep Records?\nEveryone in business must keep records. Good records \nwill help you do the following.\nMonitor the progress of your business. You need \ngood records to monitor the progress of your business. \nRecords can show whether your business is improving, \nwhich items are selling, or what changes you need to \nmake. Good records can increase the likelihood of busi-\nness success.\nPrepare your financial statements. You need good re-\ncords to prepare accurate financial statements. These in-\nclude income (profit and loss) statements and balance \nsheets. These statements can help you in dealing with \nyour bank or creditors and help you manage your busi-\nness.\n• An income statement shows the income and expen-\nses of the business for a given period of time.\n• A balance sheet shows the assets, liabilities, and your \nequity in the business on a given date.\nIdentify source of receipts. You will receive money or \nproperty from many sources. Your records can identify the \nsource of your receipts. You need this information to sep-\narate business from nonbusiness receipts and taxable \nfrom nontaxable income.\nKeep track of deductible expenses. You may forget \nexpenses when you prepare your tax return unless you re-\ncord them when they occur.\nPrepare your tax returns. You need good records to \nprepare your tax returns. These records must support the \nincome, expenses, and credits you report. Generally, \nthese are the same records you use to monitor your busi-\nness and prepare your financial statements.\nPublication 583 (January 2021)\n Page 11\n", "Support items reported on tax returns. You must keep \nyour business records available at all times for inspection \nby the IRS. If the IRS examines any of your tax returns, \nyou may be asked to explain the items reported. A com-\nplete set of records will speed up the examination.\nKinds of Records To Keep\nExcept in a few cases, the law does not require any spe-\ncific kind of records. You can choose any recordkeeping \nsystem suited to your business that clearly shows your in-\ncome and expenses.\nThe business you are in affects the type of records you \nneed to keep for federal tax purposes. You should set up \nyour recordkeeping system using an accounting method \nthat clearly shows your income for your tax year. See \nChoosing an Accounting Method, earlier. If you are in \nmore than one business, you should keep a complete and \nseparate set of records for each business. A corporation \nshould keep minutes of board of directors' meetings.\nYour recordkeeping system should include a summary \nof your business transactions. This summary is ordinarily \nmade in your books (for example, accounting journals and \nledgers). Your books must show your gross income, as \nwell as your deductions and credits. For most small busi-\nnesses, the business checkbook (discussed later) is the \nmain source for entries in the business books. In addition, \nyou must keep supporting documents, explained later.\nElectronic records. All requirements that apply to hard \ncopy books and records also apply to electronic storage \nsystems that maintain tax books and records. When you \nreplace hard copy books and records, you must maintain \nthe electronic storage systems for as long as they are ma-\nterial to the administration of tax law. An electronic stor-\nage system is any system for preparing or keeping your \nrecords either by electronic imaging or by transfer to an \nelectronic storage media. The electronic storage system \nmust index, store, preserve, retrieve, and reproduce the \nelectronically stored books and records in legible format. \nAll electronic storage systems must provide a complete \nand accurate record of your data that is accessible to the \nIRS. Electronic storage systems are also subject to the \nsame controls and retention guidelines as those imposed \non your original hard copy books and records.\nThe original hard copy books and records may be de-\nstroyed provided that the electronic storage system has \nbeen tested to establish that the hard copy books and re-\ncords are being reproduced in compliance with IRS re-\nquirements for an electronic storage system and proce-\ndures are established to ensure continued compliance \nwith all applicable rules and regulations. You still have the \nresponsibility of retaining any other books and records \nthat are required to be retained.\nThe IRS may test your electronic storage system, in-\ncluding the equipment used, indexing methodology, soft-\nware and retrieval capabilities. This test is not considered \nan examination and the results must be shared with you. If \nyour electronic storage system meets the requirements \nmentioned earlier, you will be in compliance. If not, you \nmay be subject to penalties for non-compliance, unless \nyou continue to maintain your original hard copy books \nand records in a manner that allows you and the IRS to \ndetermine your correct tax.\nFor details on electronic storage system requirements, \nsee Revenue Procedure 97-22, available at IRS.gov/Tax-\nExempt-Bonds/Revenue-Procedures.\nSupporting Documents\nPurchases, sales, payroll, and other transactions you \nhave in your business generate supporting documents. \nSupporting documents include sales slips, paid bills, in-\nvoices, receipts, deposit slips, and canceled checks. \nThese documents contain information you need to record \nin your books.\nIt is important to keep these documents because they \nsupport the entries in your books and on your tax return. \nKeep them in an orderly fashion and in a safe place. For \ninstance, organize them by year and type of income or ex-\npense.\nGross receipts. Gross receipts are the income you re-\nceive from your business. You should keep supporting \ndocuments that show the amounts and sources of your \ngross receipts. Documents that show gross receipts in-\nclude the following.\n• Cash register tapes.\n• Bank deposit slips.\n• Receipt books.\n• Invoices.\n• Credit card charge slips.\n• Forms 1099-MISC.\n• Forms 1099-NEC.\nInventory. Inventory is any item you buy and resell to \ncustomers. If you are a manufacturer or producer, this in-\ncludes the cost of all raw materials or parts purchased for \nmanufacture into finished products. Your supporting docu-\nments should show the amount paid and that the amount \nwas for inventory. Documents reporting the cost of inven-\ntory include the following.\n• Canceled checks.\n• Cash register tape receipts.\n• Credit card sales slips.\n• Invoices.\nThese records will help you determine the value of your in-\nventory at the end of the year. See Pub. 538 for informa-\ntion on methods for valuing inventory.\nExpenses. Expenses are the costs you incur (other than \nthe cost of inventory) to carry on your business. Your sup-\nporting documents should show the amount paid and that \nthe amount was for a business expense. Documents for \nexpenses include the following.\n• Canceled checks.\nPage 12 \nPublication 583 (January 2021)\n", "• Cash register tapes.\n• Account statements.\n• Credit card sales slips.\n• Invoices.\n• Petty cash slips for small cash payments.\nA petty cash fund allows you to make small pay-\nments without having to write checks for small \namounts. Each time you make a payment from \nthis fund, you should make out a petty cash slip and at-\ntach it to your receipt as proof of payment.\nTravel, transportation, and gift expenses. Specific \nrecordkeeping rules apply to these expenses. For more \ninformation, see Pub. 463.\nEmployment taxes. There are specific employment \ntax records you must keep. For a list, see Pub. 15.\nAssets. Assets are the property, such as machinery and \nfurniture you own and use in your business. You must \nkeep records to verify certain information about your busi-\nness assets. You need records to figure the annual depre-\nciation and the gain or loss when you sell the assets. Your \nrecords should show the following information.\n• When and how you acquired the asset.\n• Purchase price.\n• Cost of any improvements.\n• Section 179 deduction taken.\n• Deductions taken for depreciation.\n• Deductions taken for casualty losses, such as losses \nresulting from fires or storms.\n• How you used the asset.\n• When and how you disposed of the asset.\n• Selling price.\n• Expenses of sale.\nThe following documents may show this information.\n• Purchase and sales invoices.\n• Real estate closing statements.\n• Canceled checks.\nWhat if I don't have a canceled check? If you do not \nhave a canceled check, you may be able to prove pay-\nment with certain financial account statements prepared \nby financial institutions. These include account statements \nprepared for the financial institution by a third party. These \naccount statements must be highly legible. The following \ntable lists acceptable account statements.\nTIP\nIF payment is by...\nTHEN the statement must \nshow the...\nCheck\n• Check number.\n• Amount.\n• Payee's name.\n• Date the check amount \nwas posted to the \naccount by the financial \ninstitution.\nElectronic funds transfer\n• Amount transferred.\n• Payee's name.\n• Date the transfer was \nposted to the account by \nthe financial institution.\nCredit card\n• Amount charged.\n• Payee's name.\n• Transaction date.\nProof of payment of an amount, by itself, does not \nestablish you are entitled to a tax deduction. You \nshould also keep other documents, such as credit \ncard sales slips and invoices, to show that you also incur-\nred the cost.\nRecording Business Transactions\nA good recordkeeping system includes a summary of your \nbusiness transactions. (Your business transactions are \nshown on the supporting documents just discussed.) \nBusiness transactions are ordinarily summarized in books \ncalled journals and ledgers. You can buy them over the In-\nternet and at your local stationery or office supply store.\nA journal is a book where you record each business \ntransaction shown on your supporting documents. You \nmay have to keep separate journals for transactions that \noccur frequently.\nA ledger is a book that contains the totals from all of \nyour journals. It is organized into different accounts.\nWhether you keep journals and ledgers and how you \nkeep them depends on the type of business you are in. \nFor example, a recordkeeping system for a small busi-\nness might include the following items.\n• Business checkbook.\n• Daily summary of cash receipts.\n• Monthly summary of cash receipts.\n• Check disbursements journal.\n• Depreciation worksheet.\n• Employee compensation record.\nThe business checkbook is explained next. The other \nitems are illustrated later under Recordkeeping System \nExample.\nCAUTION\n!\nPublication 583 (January 2021)\n Page 13\n", "The system you use to record business transac-\ntions will be more effective if you follow good re-\ncordkeeping practices. For example, record ex-\npenses when they occur, and identify the source of \nrecorded receipts. Generally, it is best to record transac-\ntions on a daily basis.\nBusiness checkbook. One of the first things you should \ndo when you start a business is open a business checking \naccount. You should keep your business account sepa-\nrate from your personal checking account.\nThe business checkbook is your basic source of infor-\nmation for recording your business expenses. You should \ndeposit all daily receipts in your business checking ac-\ncount. You should check your account for errors by recon-\nciling it. See Reconciling the checking account, later.\nConsider using a checkbook that allows enough space \nto identify the source of deposits as business income, per-\nsonal funds, or loans. You should also note on the deposit \nslip the source of the deposit and keep copies of all slips.\nYou should make all payments by check to document \nbusiness expenses. Write checks payable to yourself only \nwhen making withdrawals from your business for personal \nuse. Avoid writing checks payable to cash. If you must \nwrite a check for cash to pay a business expense, include \nthe receipt for the cash payment in your records. If you \ncannot get a receipt for a cash payment, you should make \nan adequate explanation in your records at the time of \npayment.\nUse the business account for business purposes \nonly. Indicate the source of deposits and the type \nof expense in the checkbook.\nReconciling the checking account. When you re-\nceive your bank statement, make sure the statement, your \ncheckbook, and your books agree. The statement balance \nmay not agree with the balance in your checkbook and \nbooks if the statement:\n• Includes bank charges you did not enter in your books \nand subtract from your checkbook balance, or\n• Does not include deposits made after the statement \ndate or checks that did not clear your account before \nthe statement date.\nBy reconciling your checking account, you will:\n• Verify how much money you have in the account,\n• Make sure that your checkbook and books reflect all \nbank charges and the correct balance in the checking \naccount, and\n• Correct any errors in your bank statement, checkbook, \nand books.\nYou should reconcile your checking account each \nmonth. \nBefore you reconcile your monthly bank statement, \ncheck your own figures. Begin with the balance shown in \nyour checkbook at the end of the previous month. To this \nbalance, add the total cash deposited during the month \nand subtract the total cash disbursements.\nTIP\nTIP\nTIP\nAfter checking your figures, the result should agree with \nyour checkbook balance at the end of the month. If the re-\nsult does not agree, you may have made an error in re-\ncording a check or deposit. You can find the error by do-\ning the following.\n1. Adding the amounts on your check stubs and com-\nparing that total with the total in the “amount of check” \ncolumn in your check disbursements journal. If the to-\ntals do not agree, check the individual amounts to see \nif an error was made in your check stub record or in \nthe related entry in your check disbursements journal.\n2. Adding the deposit amounts in your checkbook. Com-\npare that total with the monthly total in your cash re-\nceipt book, if you have one. If the totals do not agree, \ncheck the individual amounts to find any errors.\nIf your checkbook and journal entries still disagree, \nthen refigure the running balance in your checkbook to \nmake sure additions and subtractions are correct.\nWhen your checkbook balance agrees with the balance \nfigured from the journal entries, you may begin reconciling \nyour checkbook with the bank statement. Many banks \nprint a reconciliation worksheet on the back of the state-\nment.\nTo reconcile your account, follow these steps.\n1. Compare the deposits listed on the bank statement \nwith the deposits shown in your checkbook. Note all \ndifferences in the dollar amounts.\n2. Compare each canceled check, including both check \nnumber and dollar amount, with the entry in your \ncheckbook. Note all differences in the dollar amounts. \nMark the check number in the checkbook as having \ncleared the bank. After accounting for all checks re-\nturned by the bank, those not marked in your check-\nbook are your outstanding checks.\n3. Prepare a bank reconciliation. One is illustrated later \nunder Recordkeeping System Example.\n4. Update your checkbook and journals for items shown \non the reconciliation as not recorded (such as service \ncharges) or recorded incorrectly.\nAt this point, the adjusted bank statement balance should \nequal your adjusted checkbook balance. If you still have \ndifferences, check the previous steps to find the errors.\nPage 14 \nPublication 583 (January 2021)\n", "Bookkeeping System\nYou must decide whether to use a single-entry or a dou-\nble-entry bookkeeping system. The single-entry system of \nbookkeeping is the simplest to maintain, but it may not be \nsuitable for everyone. You may find the double-entry sys-\ntem better because it has built-in checks and balances to \nassure accuracy and control.\nSingle-entry. A single-entry system is based on the in-\ncome statement (profit or loss statement). It can be a sim-\nple and practical system if you are starting a small busi-\nness. The system records the flow of income and \nexpenses through the use of:\n1. A daily summary of cash receipts, and\n2. Monthly summaries of cash receipts and disburse-\nments.\nDouble-entry. A double-entry bookkeeping system uses \njournals and ledgers. Transactions are first entered in a \njournal and then posted to ledger accounts. These ac-\ncounts show income, expenses, assets (property a busi-\nness owns), liabilities (debts of a business), and net worth \n(excess of assets over liabilities). You close income and \nexpense accounts at the end of each tax year. You keep \nasset, liability, and net worth accounts open on a perma-\nnent basis.\nIn the double-entry system, each account has a left \nside for debits and a right side for credits. It is self-balanc-\ning because you record every transaction as a debit entry \nin one account and as a credit entry in another.\nUnder this system, the total debits must equal the total \ncredits after you post the journal entries to the ledger ac-\ncounts. If the amounts do not balance, you have made an \nerror and you must find and correct it.\nAn example of a journal entry exhibiting a payment of \nrent in October is shown next.\nGeneral Journal\nDate\n Description of Entry\n Debit\n Credit\nOct. 5\n Rent expense\n780.00\n Cash\n780.00\nComputerized System\nThere are computer software packages you can use for \nrecordkeeping. They can be purchased over the Internet \nand in many retail stores. These packages are very help-\nful and relatively easy to use; they require very little knowl-\nedge of bookkeeping and accounting.\nIf you use a computerized system, you must be able to \nproduce sufficient legible records to support and verify en-\ntries made on your return and determine your correct tax \nliability. To meet this qualification, the machine-sensible \nrecords must reconcile with your books and return. These \nrecords must provide enough detail to identify the underly-\ning source documents.\nYou must also keep all machine-sensible records and a \ncomplete description of the computerized portion of your \nrecordkeeping system. This documentation must be suffi-\nciently detailed to show all of the following items.\n• Functions being performed as the data flows through \nthe system.\n• Controls used to ensure accurate and reliable pro-\ncessing.\n• Controls used to prevent the unauthorized addition, al-\nteration, or deletion of retained records.\n• Charts of accounts and detailed account descriptions.\nFor more information, see Revenue Procedure 98-25 in \nCumulative \nBulletin \n1998-1, \navailable \nat \nIRS.gov/\nBusinesses/Automated-Records.\nTable 3. Period of Limitations\nIF you...\nTHEN the period is...\n1. Owe additional tax and situations (2), (3), and (4), below, do not apply to you\n3 years\n2. Do not report income that you should report and it is more than 25% of the gross \nincome shown on the return\n6 years\n3. File a fraudulent return\nNot limited\n4. Do not file a return\nNot limited\n5. File a claim for credit or refund after you filed your return\nLater of: 3 years or \n2 years after tax \n was paid\n6. File a claim for a loss from worthless securities or a bad debt deduction\n7 years\nPublication 583 (January 2021)\n Page 15\n", "How Long To Keep Records\nYou must keep your records as long as they may be nee-\nded for the administration of any provision of the Internal \nRevenue Code. Generally, this means you must keep re-\ncords that support an item of income or deduction on a re-\nturn until the period of limitations for that return runs out.\nThe period of limitations is the period of time in which \nyou can amend your return to claim a credit or refund, or \nthe IRS can assess additional tax. Table 3 contains the \nperiods of limitations that apply to income tax returns. Un-\nless otherwise stated, the years refer to the period after \nthe return was filed. Returns filed before the due date are \ntreated as filed on the due date.\nKeep copies of your filed tax returns. They help in \npreparing future tax returns and making computa-\ntions if you file an amended return.\nEmployment taxes. If you have employees, you must \nkeep all employment tax records for at least 4 years after \nthe date the tax becomes due or is paid, whichever is \nlater. For more information about recordkeeping for em-\nployment taxes, see Pub. 15.\nAssets. Keep records relating to property until the period \nof limitations expires for the year in which you dispose of \nthe property in a taxable disposition. You must keep these \nrecords to figure any depreciation, amortization, or deple-\ntion deduction, and to figure your basis for computing gain \nor loss when you sell or otherwise dispose of the property.\nGenerally, if you received property in a nontaxable ex-\nchange, your basis in that property is the same as the ba-\nsis of the property you gave up, increased by any money \nyou paid. You must keep the records on the old property, \nas well as on the new property, until the period of limita-\ntions expires for the year in which you dispose of the new \nproperty in a taxable disposition.\nRecords for nontax purposes. When your records are \nno longer needed for tax purposes, do not discard them \nuntil you check to see if you have to keep them longer for \nother purposes. For example, your insurance company or \ncreditors may require you to keep them longer than the \nIRS does.\nRecordkeeping System Example\nThis example illustrates a single-entry system used by \nHenry Brown, who is the sole proprietor of a small auto-\nmobile body shop. Henry uses part-time help, has no in-\nventory of items held for sale, and uses the cash method \nof accounting.\nThese sample records should not be viewed as a rec-\nommendation of how to keep your records. They are in-\ntended only to show how one business keeps its records.\n1. Daily Summary of Cash Receipts\nThis summary is a record of cash sales for the day. It ac-\ncounts for cash at the end of the day over the amount in \nTIP\nthe Change and Petty Cash Fund at the beginning of the \nday.\nHenry takes the cash sales entry from his cash register \ntape. If he had no cash register, he would simply total his \ncash sale slips and any other cash received that day.\nHe carries the total receipts shown in this summary for \nJanuary 3 ($267.80), including cash sales ($263.60) and \nsales tax ($4.20), to the Monthly Summary of Cash Re-\nceipts.\nPetty cash fund. Henry uses a petty cash fund to make \nsmall payments without having to write checks for small \namounts. Each time he makes a payment from this fund, \nhe makes out a petty cash slip and attaches it to his re-\nceipt as proof of payment. He sets up a fixed amount \n($50) in his petty cash fund. The total of the unspent petty \ncash and the amounts on the petty cash slips should \nequal the fixed amount of the fund. When the totals on the \npetty cash slips approach the fixed amount, he brings the \ncash in the fund back to the fixed amount by writing a \ncheck to “Petty Cash” for the total of the outstanding slips. \n(See the Check Disbursements Journal entry for check \nnumber 92.) This restores the fund to its fixed amount of \n$50. He then summarizes the slips and enters them in the \nproper columns in the monthly check disbursements jour-\nnal.\n2. Monthly Summary of Cash Receipts\nThis shows the income activity for the month. Henry car-\nries the total monthly net sales shown in this summary for \nJanuary ($4,865.05) to his Annual Summary.\nTo figure total monthly net sales, Henry reduces the to-\ntal monthly receipts by the sales tax imposed on his cus-\ntomers and turned over to the state. He cannot take a de-\nduction for sales tax turned over to the state because he \nonly collected the tax. He does not include the tax in his \nincome.\n3. Check Disbursements Journal\nHenry enters checks drawn on the business checking ac-\ncount in the Check Disbursements Journal each day. All \nchecks are prenumbered and each check number is listed \nand accounted for in the column provided in the journal.\nFrequent expenses have their own headings across the \nsheet. He enters in a separate column expenses that re-\nquire comparatively numerous or large payments each \nmonth, such as materials, gross payroll, and rent. Under \nthe General Accounts column, he enters small expenses \nthat normally have only one or two monthly payments, \nsuch as licenses and postage.\nHenry does not pay personal or nonbusiness expenses \nby checks drawn on the business account. If he did, he \nwould record them in the journal, even though he could \nnot deduct them as business expenses.\nPage 16 \nPublication 583 (January 2021)\n", "Henry carries the January total of expenses for materi-\nals ($1,083.50) to the Annual Summary. Similarly, he en-\nters the monthly total of expenses for telephone, truck/\nauto, etc., in the appropriate columns of that summary.\n4. Employee Compensation Record\nThis record shows the following information.\n• The number of hours Henry's employee worked in a \npay period.\n• The employee's total pay for the period.\n• The deductions Henry withheld in figuring the employ-\nee's net pay.\n• The monthly gross payroll.\nHenry carries the January gross payroll ($520) to the An-\nnual Summary.\n5. Annual Summary\nThis annual summary of monthly cash receipts and ex-\npense totals provides the final amounts to enter on \nHenry's tax return. He figures the cash receipts total from \nthe total of monthly cash receipts shown in the Monthly \nSummary of Cash Receipts. He figures the expense totals \nfrom the totals of monthly expense items shown in the \nCheck Disbursements Journal. As in the journal, he keeps \neach major expense in a separate column.\nHenry carries the cash receipts total shown in the an-\nnual summary ($47,440.95) to Part I of Schedule C (not il-\nlustrated). He carries the total for materials ($10,001.00) \nto Part II of Schedule C.\nA business that keeps materials and supplies on \nhand generally must complete the inventory lines \nin Part III of Schedule C. However, there are no \ninventories of materials and supplies in this example. \nHenry buys parts and supplies on a per-job basis; he does \nnot keep them on hand.\nHenry enters annual totals for interest, rent, taxes, and \nwages on the appropriate lines in Part II of Schedule C. \nThe total for taxes and licenses includes the employer's \nshare of social security and Medicare taxes, and the busi-\nness license fee. He enters the total of other annual busi-\nness expenses on the “Other expenses” line of Sched-\nule C.\nCAUTION\n!\n6. Depreciation Worksheet\nThis worksheet shows the information used in figuring the \ndepreciation allowed on assets used in Henry's business. \nHenry figures the depreciation using the modified acceler-\nated cost recovery system (MACRS). He purchased and \nplaced in service several used assets that do not qualify \nfor the section 179 deduction. Depreciation and the sec-\ntion 179 deduction are discussed in Pub. 946. Henry uses \nthe information in the worksheet to complete Form 4562, \nDepreciation and Amortization (not illustrated).\n7. Bank Reconciliation\nHenry reconciles his checkbook with his bank statement \nand prepares a bank reconciliation for January as follows.\n1. Henry begins by entering his bank statement balance.\n2. Henry compares the deposits listed on the bank state-\nment with deposits shown in his checkbook. Two de-\nposits shown in his checkbook— $701.33 and \n$516.08—were not on his bank statement. He enters \nthese two amounts on the bank reconciliation. He \nadds them to the bank statement balance of \n$1,458.12 to arrive at a subtotal of $2,675.53.\n3. After comparing each canceled check with his check-\nbook, Henry found four outstanding checks totaling \n$526.50. He subtracts this amount from the subtotal \nin (2). The result of $2,149.03 is the adjusted bank \nstatement balance.\n4. Henry enters his checkbook balance on the bank rec-\nonciliation.\n5. Henry discovered that he mistakenly entered a de-\nposit of $600.40 in his checkbook as $594.40. He \nadds the difference ($6.00) to the checkbook balance \nof $2,153.03. There was a $10.00 bank service \ncharge on his bank statement that he subtracts from \nthe checkbook balance. The result is the adjusted \ncheckbook balance of $2,149.03. This equals his ad-\njusted bank statement balance computed in (3).\nThe only book adjustment Henry needs to make is to \nthe Check Disbursements Journal for the $10 bank serv-\nice charge. He does not need to adjust the Monthly Sum-\nmary of Cash Receipts because he correctly entered the \nJanuary 8 deposit of $600.40 in that record.\nPublication 583 (January 2021)\n Page 17\n", "Daily Cash Receipts\n1. Daily Summary of Cash Receipts\nDate\nTOTAL RECEIPTS\nCash sales\nSales tax\nCash in register (including unspent petty cash)\nCash on hand\nCoins\nBills\nChecks\nTOTAL CASH IN REGISTER\nAdd: Petty cash slips\nTOTAL CASH\nLess: Change and petty cash\nPetty cash slips\nCoins and bills\n(unspent petty cash)\nTOTAL CHANGE AND PETTY CASH FUND\nTOTAL CASH RECEIPTS\n\u0001\n\u0001\nJanuary 3, 20 —\n263.60\n4.20\n267.80\n300.80\n17.00\n317.80\n50.00\n267.80\n17.00\n33.00\n23.75\n143.00\n134.05\nPage 18 \nPublication 583 (January 2021)\n", "2. Monthly Summary of Cash Receipts\nYear \n20—\n \nMonth \nJanuary\n \nDay\nNet Sales\nSales Tax\nDaily Receipts\nDeposit\n3\n263.60\n4.20\n267.80\n \n4\n212.00\n3.39\n215.39\n5\n194.40\n3.10\n197.50\n680.69\n6\n222.40\n3.54\n225.94\n7\n231.15\n3.68\n234.83\n8\n137.50\n2.13\n139.63\n600.40\n10\n187.90\n2.99\n190.89\n11\n207.56\n3.31\n210.87\n401.76\n12\n128.95\n2.05\n131.00\n13\n231.40\n3.77\n235.17\n14\n201.28\n3.21\n204.49\n15\n88.01\n1.40\n89.41\n660.07\n17\n210.95\n3.36\n214.31\n18\n221.80\n3.53\n225.33\n439.64\n19\n225.15\n3.59\n228.74\n20\n221.93\n3.52\n225.45\n21\n133.53\n2.13\n135.66\n589.85\n22\n130.84\n2.08\n132.92\n24\n216.37\n3.45\n219.82\n352.74\n25\n220.05\n3.50\n223.55\n26\n197.80\n3.15\n200.95\n27\n272.49\n4.34\n276.83\n701.33\n28\n150.64\n2.40\n153.04\n29\n224.05\n3.56\n227.61\n \n31\n133.30\n2.13\n135.43\n516.08\nTOTALS\n4,865.05\n77.51\n4,942.56\n4,942.56\nPublication 583 (January 2021)\n Page 19\n", "3. Check Disbursements Journal\nYear 20— Month January\nDay\nPaid To\nCheck #\nAmount of \nCheck\nMaterials\nGross \nPayroll\nFederal \nWithheld \nIncome \nTax\nFICA Social \nSecurity \nReserve\nFICA \nMedicare \nReserve\n3\nDale Advertising\n74\n85.00\n4\nCity Treasurer\n75\n35.00\n4\nAuto Parts, Inc.\n76\n203.00\n203.00\n4\nJohn E. Marks\n77\n214.11\n260.00\n(20.00)\n(16.12)\n(3.77)\n6\nHenry Brown\n78\n250.00\n6\nMike's Deli\n79\n36.00\n6\nJoe's Service \nStation\n80\n74.50\n29.50\n6\nABC Auto Paint\n81\n137.50\n137.50\n7\nHenry Brown\n82\n225.00\n14\nTelephone Co.\n83\n27.00\n15\nNational Bank (Tax \nDeposit)\n84\n119.56\n40.00\n32.24\n 7.54\n18\nNational Bank\n85\n90.09\n18\nAuto Parts, Inc.\n86\n472.00\n472.00\n18\nHenry Brown\n87\n275.00\n18\nJohn E. Marks\n88\n214.11\n260.00\n(20.00)\n(16.12)\n(3.77)\n21\nElectric Co.\n89\n175.30\n21\nM.B. Ignition\n90\n66.70\n66.70\n21\nBaker's Fender Co.\n91\n9.80\n9.80\n21\nPetty Cash\n92\n17.00\n15.00\n21\nHenry Brown\n93\n225.00\n25\nBaker's Fender Co.\n94\n150.00\n150.00\n25\nEnterprise \nProperties\n95\n300.00\n25\nState Treasurer\n96\n12.00\n25\nState Treasurer\n97\n65.00\n3,478.67\n1,083.50\n520.00\n-0-\n -0-\n-0-\nBank service \ncharge\n10.00\nTOTALS\n3,488.67\n1,083.50\n520.00\n-0-\n -0-\n-0- \nPage 20 \nPublication 583 (January 2021)\n", "3. Check Disbursements Journal (Continued)\n \nState \nWithheld \nIncome Tax\n \nEmployer's \n FICA \nTax\nElectric Interest\n Rent\nTelephone\nTruck/\nAuto\nDrawing\nGeneral Accounts\nAdvertising\n85.00\nLicense\n35.00\n (6.00)\n250.00\nHoliday Party\n36.00\n45.00\n225.00\n27.00\n39.78\n18.09\nLoan\n72.00\n275.00\n(6.00)\n175.30\nPostage\n2.00\n225.00\n300.00\n12.00\nSales Tax\n65.00\n-0- \n39.78 175.30\n18.09\n300.00\n27.00\n45.00\n975.00\n295.00\n10.00\n-0- \n39.78 175.30\n18.09\n300.00\n27.00\n45.00\n975.00\n305.00\nPublication 583 (January 2021)\n Page 21\n", "Employee Compensation\n4. Employee Compensation Record\nPay\nPeriod\nEnding\nDate\nPaid\nS M T W T F S\nS M T W T F S\nTotal\nRegular\nHours\nOvertime\nRegular\nRate\nOvertime\nRate\nTotal\nSocial\nSecurity\n.\n.\n.\nMedicare\nFederal\nIncome\nTax\nState\nIncome\nTax\nNet Pay\nEarnings\nDeductions\nHours Worked\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nName\nQUARTERLY TOTALS\nAddress\nPhone\nSoc. Sec. No.\nDate of Birth\nFiling Status \nFull Time\nPart Time\n5. Annual Summary\nMonth\nCash\nReceipts\nGross\nPayroll\nFICA\nTaxes\nBank\nCharges Electric\nInterest\nInsurance\nRent\nTelephones\nTruck/\n.\nc\ns\ni\nM\no\nt\nu\nA\nMaterials/\nSupplies\nAdvertising\nOfﬁce\nExpenses\nTaxes/\nLicenses\nTOTALS\n6. Depreciation Worksheet\nDescription of Property\nDate Placed\nin Service\nCost or\nOther Basis\nBusiness/\nInvestment\nUse %\nSection 179\nDeduction\nand Special\nAllowance\nDepreci-\nation Prior\nYears\nBasis for\nDepreciation\nMethod/\nConvention\nRecovery\nPeriod\nRate or\nTable %\nDepreciation\nDeduction\n1 Elm St., Anytown, NJ 07101\nJohn E. Marks\n555-6075\n567-00-8901\n12-21-65\nSingle\nX\n80\n$6.50\n.\n$6.50\n$260.00\n$260.00\n$520.00\n$1,262.40\n$16.12 $3.77\n$20.00 $6.00 $214.11\n$16.12 $3.77\n$20.00 $6.00 $214.11\n$32.24 $7.54\n$40.00 $12.00 $428.22\n$78.23 $18.31$100.00 $30.00 $1,035.86\nJanuary\nFebruary\nMarch\nDecember\n$4,865.05\n3,478.32\n3,942.00\n3,656.52\n$47,440.95\n$420.00\n$1,083.50\n874.93\n724.90\n609.23\n$10,001.00\n$520.00\n235.40\n507.00\n520.00\n$5,434.00\n$39.78\n17.68\n38.08\n39.78\n$408.09\n$10.00\n7.50\n11.25\n10.00\n$92.30\n$175.30\n153.10\n145.81\n169.00\n$1,642.37\n$18.09\n18.09\n18.09\n18.09\n$217.08\n210.00\n$300.00\n300.00\n300.00\n300.00\n$3,600.00\n$27.00 $45.00 $85.00 $36.00 $100.00 $2.00\n71.91\n21.50\n32.10\n23.13\n28.50\n51.30\n37.62\n4.00\n$324.09 $571.46\n$344.00\n$218.00\n$85.00 $40.00\nUsed Equipment—\nTransmission Jack\nUsed Pickup Truck\nUsed Heavy Duty\nTow Truck\nUsed Equipment—\nEngine Hoist\n1 - 3\n1 - 3\n1 - 3\n1 - 3\n3,000\n100%\n3,000\n—\n—\n8,000\n100%\n8,000\n—\n—\n30,000\n100%\n30,000\n—\n—\n4,000\n100%\n4,000\n—\n—\n200 DB/HY\n200 DB/HY\n200 DB/HY\n200 DB/HY\n$429\n7\n14.29%\n7\n14.29%\n572\n5\n20%\n5\n20%\n$8,601\n 1 - 15 \n 1 - 18 4 4 4 4 4 2\n 40\n4 3 4 4 3\n 1 - 1 1 - 4 5 5 5 5\n5 5 4 6\n 40\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nPage 22 \nPublication 583 (January 2021)\n", "Bank Reconciliation\n7. Bank Reconciliation as of\nDate\nTOTAL DEPOSITS NOT CREDITED\nClosing balance shown on bank statement\nAdd deposits not credited:\nSubtract outstanding checks:\nNo.\nTOTAL OUTSTANDING CHECKS\nBalance shown in checkbook\nAdd:\nSubtract:\nAdjusted checkbook balance\n\u0001\n\u0001\nJanuary 31, 20 —\n1,458.12\n701.33\n1,217.41\n526.50\n2,153.03\n6.00\n2,149.03\n2,159.03\n10.00\n66.70\n9.80\n300.00\n516.08\n1/28\n1/31\nSubtotal\n2,675.53\n150.00\n90\n91\n94\n95\n2,149.03\nAdjusted balance per bank statement\nDeposit of $600.40 for\n1/8 entered as\n$594.40 (difference)\nBank service charge\nPublication 583 (January 2021)\n Page 23\n", "How To Get Tax Help\nIf you have questions about a tax issue, need help prepar-\ning your tax return, or want to download free publications, \nforms, or instructions, go to IRS.gov and find resources \nthat can help you right away.\nPreparing and filing your tax return. After receiving all \nyour wage and earnings statements (Form W-2, W-2G, \n1099-R, 1099-MISC, 1099-NEC, etc.); unemployment \ncompensation statements (by mail or in a digital format) or \nother government payment statements (Form 1099-G); \nand interest, dividend, and retirement statements from \nbanks and investment firms (Forms 1099), you have sev-\neral options to choose from to prepare and file your tax re-\nturn. You can prepare the tax return yourself, see if you \nqualify for free tax preparation, or hire a tax professional to \nprepare your return.\nFree options for tax preparation. Go to IRS.gov to see \nyour options for preparing and filing your return online or \nin your local community, if you qualify, which include the \nfollowing.\n• Free File. This program lets you prepare and file your \nfederal individual income tax return for free using \nbrand-name tax-preparation-and-filing software or \nFree File fillable forms. However, state tax preparation \nmay not be available through Free File. Go to IRS.gov/\nFreeFile to see if you qualify for free online federal tax \npreparation, e-filing, and direct deposit or payment op-\ntions.\n• VITA. The Volunteer Income Tax Assistance (VITA) \nprogram offers free tax help to people with \nlow-to-moderate incomes, persons with disabilities, \nand limited-English-speaking taxpayers who need \nhelp preparing their own tax returns. Go to IRS.gov/\nVITA, download the free IRS2Go app, or call \n800-906-9887 for information on free tax return prepa-\nration.\n• TCE. The Tax Counseling for the Elderly (TCE) pro-\ngram offers free tax help for all taxpayers, particularly \nthose who are 60 years of age and older. TCE volun-\nteers specialize in answering questions about pen-\nsions and retirement-related issues unique to seniors. \nGo to IRS.gov/TCE, download the free IRS2Go app, \nor call 888-227-7669 for information on free tax return \npreparation.\n• MilTax. Members of the U.S. Armed Forces and \nqualified veterans may use MilTax, a free tax service \noffered by the Department of Defense through Military \nOneSource.\nAlso, the IRS offers Free Fillable Forms, which can \nbe completed online and then filed electronically re-\ngardless of income.\nUsing online tools to help prepare your return. Go to \nIRS.gov/Tools for the following.\n• The Earned Income Tax Credit Assistant (IRS.gov/\nEITCAssistant) determines if you’re eligible for the \nearned income credit (EIC).\n• The Online EIN Application (IRS.gov/EIN) helps you \nget an employer identification number (EIN).\n• The Tax Withholding Estimator (IRS.gov/W4app) \nmakes it easier for everyone to pay the correct amount \nof tax during the year. The tool is a convenient, online \nway to check and tailor your withholding. It’s more \nuser-friendly for taxpayers, including retirees and \nself-employed individuals. The features include the \nfollowing.\n– Easy to understand language.\n– The ability to switch between screens, correct pre-\nvious entries, and skip screens that don’t apply.\n– Tips and links to help you determine if you qualify \nfor tax credits and deductions.\n– A progress tracker.\n– A self-employment tax feature.\n– Automatic calculation of taxable social security ben-\nefits.\n• The First Time Homebuyer Credit Account Look-up \n(IRS.gov/HomeBuyer) tool provides information on \nyour repayments and account balance.\n• The Sales Tax Deduction Calculator (IRS.gov/\nSalesTax) figures the amount you can claim if you \nitemize deductions on Schedule A (Form 1040).\nGetting answers to your tax questions. On \nIRS.gov, you can get up-to-date information on \ncurrent events and changes in tax law.\n• IRS.gov/Help: A variety of tools to help you get an-\nswers to some of the most common tax questions.\n• IRS.gov/ITA: The Interactive Tax Assistant, a tool that \nwill ask you questions on a number of tax law topics \nand provide answers.\n• IRS.gov/Forms: Find forms, instructions, and publica-\ntions. You will find details on 2020 tax changes and \nhundreds of interactive links to help you find answers \nto your questions.\n• You may also be able to access tax law information in \nyour electronic filing software.\nNeed someone to prepare your tax return? There are \nvarious types of tax return preparers, including tax prepar-\ners, enrolled agents, certified public accountants (CPAs), \nattorneys, and many others who don’t have professional \ncredentials. If you choose to have someone prepare your \ntax return, choose that preparer wisely. A paid tax pre-\nparer is:\n• Primarily responsible for the overall substantive accu-\nracy of your return,\nPage 24 \nPublication 583 (January 2021)\n", "• Required to sign the return, and\n• Required to include their preparer tax identification \nnumber (PTIN).\nAlthough the tax preparer always signs the return, \nyou're ultimately responsible for providing all the informa-\ntion required for the preparer to accurately prepare your \nreturn. Anyone paid to prepare tax returns for others \nshould have a thorough understanding of tax matters. For \nmore information on how to choose a tax preparer, go to \nTips for Choosing a Tax Preparer on IRS.gov.\nCoronavirus. Go to IRS.gov/Coronavirus for links to in-\nformation on the impact of the coronavirus, as well as tax \nrelief available for individuals and families, small and large \nbusinesses, and tax-exempt organizations.\nTax reform. Tax reform legislation affects individuals, \nbusinesses, and tax-exempt and government entities. Go \nto IRS.gov/TaxReform for information and updates on \nhow this legislation affects your taxes.\nEmployers can register to use Business Services On-\nline. The Social Security Administration (SSA) offers on-\nline service at SSA.gov/employer for fast, free, and secure \nonline W-2 filing options to CPAs, accountants, enrolled \nagents, and individuals who process Form W-2, Wage \nand Tax Statement, and Form W-2c, Corrected Wage and \nTax Statement.\nIRS social media. Go to IRS.gov/SocialMedia to see the \nvarious social media tools the IRS uses to share the latest \ninformation on tax changes, scam alerts, initiatives, prod-\nucts, and services. At the IRS, privacy and security are \nparamount. We use these tools to share public informa-\ntion with you. Don’t post your SSN or other confidential in-\nformation on social media sites. Always protect your iden-\ntity when using any social networking site.\nThe following IRS YouTube channels provide short, in-\nformative videos on various tax-related topics in English, \nSpanish, and ASL.\n• Youtube.com/irsvideos.\n• Youtube.com/irsvideosmultilingua.\n• Youtube.com/irsvideosASL.\nWatching \nIRS \nvideos. The \nIRS \nVideo \nportal \n(IRSVideos.gov) contains video and audio presentations \nfor individuals, small businesses, and tax professionals.\nOnline tax information in other languages. You can \nfind information on IRS.gov/MyLanguage if English isn’t \nyour native language.\nFree interpreter service. Multilingual assistance, provi-\nded by the IRS, is available at Taxpayer Assistance Cen-\nters (TACs) and other IRS offices. Over-the-phone inter-\npreter service is accessible in more than 350 languages.\nGetting tax forms and publications. Go to IRS.gov/\nForms to view, download, or print all of the forms, instruc-\ntions, and publications you may need. You can also down-\nload and view popular tax publications and instructions \n(including the Instructions for Forms 1040 and 1040-SR) \non mobile devices as an eBook at IRS.gov/eBooks. Or \nyou can go to IRS.gov/OrderForms to place an order.\nAccess your online account (individual taxpayers \nonly). Go to IRS.gov/Account to securely access infor-\nmation about your federal tax account.\n• View the amount you owe, pay online, or set up an on-\nline payment agreement.\n• Access your tax records online.\n• Review your payment history.\n• Go to IRS.gov/SecureAccess to review the required \nidentity authentication process.\nUsing direct deposit. The fastest way to receive a tax \nrefund is to file electronically and choose direct deposit, \nwhich securely and electronically transfers your refund di-\nrectly into your financial account. Direct deposit also \navoids the possibility that your check could be lost, stolen, \nor returned undeliverable to the IRS. Eight in 10 taxpayers \nuse direct deposit to receive their refunds. The IRS issues \nmore than 90% of refunds in less than 21 days.\nGetting a transcript of your return. The quickest way \nto get a copy of your tax transcript is to go to IRS.gov/\nTranscripts. Click on either “Get Transcript Online” or “Get \nTranscript by Mail” to order a free copy of your transcript. \nIf you prefer, you can order your transcript by calling \n800-908-9946.\nReporting and resolving your tax-related identity \ntheft issues. \n• Tax-related identity theft happens when someone \nsteals your personal information to commit tax fraud. \nYour taxes can be affected if your SSN is used to file a \nfraudulent return or to claim a refund or credit.\n• The IRS doesn’t initiate contact with taxpayers by \nemail, text messages, telephone calls, or social media \nchannels to request personal or financial information. \nThis includes requests for personal identification num-\nbers (PINs), passwords, or similar information for \ncredit cards, banks, or other financial accounts.\n• Go to IRS.gov/IdentityTheft, the IRS Identity Theft \nCentral webpage, for information on identity theft and \ndata security protection for taxpayers, tax professio-\nnals, and businesses. If your SSN has been lost or \nstolen or you suspect you’re a victim of tax-related \nidentity theft, you can learn what steps you should \ntake.\n• Get an Identity Protection PIN (IP PIN). IP PINs are \nsix-digit numbers assigned to eligible taxpayers to \nhelp prevent the misuse of their SSNs on fraudulent \nfederal income tax returns. When you have an IP PIN, \nit prevents someone else from filing a tax return with \nyour SSN. To learn more, go to IRS.gov/IPPIN.\nChecking on the status of your refund. \n• Go to IRS.gov/Refunds.\nPublication 583 (January 2021)\n Page 25\n", "• The IRS can’t issue refunds before mid-February 2021 \nfor returns that claimed the EIC or the additional child \ntax credit (ACTC). This applies to the entire refund, \nnot just the portion associated with these credits.\n• Download the official IRS2Go app to your mobile de-\nvice to check your refund status.\n• Call the automated refund hotline at 800-829-1954.\nMaking a tax payment. The IRS uses the latest encryp-\ntion technology to ensure your electronic payments are \nsafe and secure. You can make electronic payments on-\nline, by phone, and from a mobile device using the \nIRS2Go app. Paying electronically is quick, easy, and \nfaster than mailing in a check or money order. Go to \nIRS.gov/Payments for information on how to make a pay-\nment using any of the following options.\n• IRS Direct Pay: Pay your individual tax bill or estima-\nted tax payment directly from your checking or sav-\nings account at no cost to you.\n• Debit or Credit Card: Choose an approved payment \nprocessor to pay online, by phone, or by mobile de-\nvice.\n• Electronic Funds Withdrawal: Offered only when filing \nyour federal taxes using tax return preparation soft-\nware or through a tax professional.\n• Electronic Federal Tax Payment System: Best option \nfor businesses. Enrollment is required.\n• Check or Money Order: Mail your payment to the ad-\ndress listed on the notice or instructions.\n• Cash: You may be able to pay your taxes with cash at \na participating retail store.\n• Same-Day Wire: You may be able to do same-day \nwire from your financial institution. Contact your finan-\ncial institution for availability, cost, and cut-off times.\nWhat if I can’t pay now? Go to IRS.gov/Payments for \nmore information about your options.\n• Apply for an online payment agreement (IRS.gov/\nOPA) to meet your tax obligation in monthly install-\nments if you can’t pay your taxes in full today. Once \nyou complete the online process, you will receive im-\nmediate notification of whether your agreement has \nbeen approved.\n• Use the Offer in Compromise Pre-Qualifier to see if \nyou can settle your tax debt for less than the full \namount you owe. For more information on the Offer in \nCompromise program, go to IRS.gov/OIC.\nFiling an amended return. You can now file Form \n1040-X electronically with tax filing software to amend \n2019 Forms 1040 and 1040-SR. To do so, you must have \ne-filed your original 2019 return. Amended returns for all \nprior years must be mailed. See Tips for taxpayers who \nneed to file an amended tax return and go to IRS.gov/\nForm1040X for information and updates.\nChecking the status of your amended return. Go to \nIRS.gov/WMAR to track the status of Form 1040-X amen-\nded returns. Please note that it can take up to 3 weeks \nfrom the date you filed your amended return for it to show \nup in our system, and processing it can take up to 16 \nweeks.\nUnderstanding an IRS notice or letter you’ve re-\nceived. Go to IRS.gov/Notices to find additional informa-\ntion about responding to an IRS notice or letter.\nContacting your local IRS office. Keep in mind, many \nquestions can be answered on IRS.gov without visiting an \nIRS Taxpayer Assistance Center (TAC). Go to IRS.gov/\nLetUsHelp for the topics people ask about most. If you still \nneed help, IRS TACs provide tax help when a tax issue \ncan’t be handled online or by phone. All TACs now pro-\nvide service by appointment, so you’ll know in advance \nthat you can get the service you need without long wait \ntimes. Before you visit, go to IRS.gov/TACLocator to find \nthe nearest TAC and to check hours, available services, \nand appointment options. Or, on the IRS2Go app, under \nthe Stay Connected tab, choose the Contact Us option \nand click on “Local Offices.”\nThe Taxpayer Advocate Service (TAS) \nIs Here To Help You\nWhat Is TAS?\nTAS is an independent organization within the IRS that \nhelps taxpayers and protects taxpayer rights. Their job is \nto ensure that every taxpayer is treated fairly and that you \nknow and understand your rights under the Taxpayer Bill \nof Rights.\nHow Can You Learn About Your Taxpayer \nRights?\nThe Taxpayer Bill of Rights describes 10 basic rights that \nall taxpayers have when dealing with the IRS. Go to \nTaxpayerAdvocate.IRS.gov to help you understand what \nthese rights mean to you and how they apply. These are \nyour rights. Know them. Use them.\nWhat Can TAS Do For You?\nTAS can help you resolve problems that you can’t resolve \nwith the IRS. And their service is free. If you qualify for \ntheir assistance, you will be assigned to one advocate \nwho will work with you throughout the process and will do \neverything possible to resolve your issue. TAS can help \nyou if:\n• Your problem is causing financial difficulty for you, \nyour family, or your business;\n• You face (or your business is facing) an immediate \nthreat of adverse action; or\n• You’ve tried repeatedly to contact the IRS but no one \nhas responded, or the IRS hasn’t responded by the \ndate promised.\nPage 26 \nPublication 583 (January 2021)\n", "How Can You Reach TAS?\nTAS has offices in every state, the District of Columbia, \nand Puerto Rico. Your local advocate’s number is in your \nlocal \ndirectory \nand \nat \nTaxpayerAdvocate.IRS.gov/\nContact-Us. You can also call them at 877-777-4778.\nHow Else Does TAS Help Taxpayers?\nTAS works to resolve large-scale problems that affect \nmany taxpayers. If you know of one of these broad issues, \nplease report it to them at IRS.gov/SAMS.\nTAS for Tax Professionals\nTAS can provide a variety of information for tax professio-\nnals, including tax law updates and guidance, TAS pro-\ngrams, and ways to let TAS know about systemic prob-\nlems you’ve seen in your practice.\nLow Income Taxpayer Clinics (LITCs)\nLITCs are independent from the IRS. LITCs represent in-\ndividuals whose income is below a certain level and need \nto resolve tax problems with the IRS, such as audits, ap-\npeals, and tax collection disputes. In addition, clinics can \nprovide information about taxpayer rights and responsibili-\nties in different languages for individuals who speak Eng-\nlish as a second language. Services are offered for free or \na small fee for eligible taxpayers. To find a clinic near you, \nvisit \nwww.TaxpayerAdvocate.IRS.gov/about-us/Low-\nIncome-Taxpayer-Clinics-LITC/ or see IRS Pub. 4134, \nLow Income Taxpayer Clinic List.\nPublication 583 (January 2021)\n Page 27\n", "To help us develop a more useful index, please let us know if you have ideas for index entries.\nSee “Comments and Suggestions” in the “Introduction” for the ways you can reach us.\nIndex\n \nA\nAccounting method:\nAccrual method 5\nCash method 5\nAssistance (See Tax help)\nB\nBusiness:\nExpenses 9\nStart-up costs 9\nTaxes 5\nUse of car 11\nUse of home 10\nC\nCar and truck expenses 11\nC corporation 3\nCorporation 3\nD\nDepositing taxes 8\nDepreciation 10\nE\nEmployer identification number \n(EIN) 3, 4\nEmployment taxes:\nDefined 7\nRecords to keep 13\nEstimated tax 6\nExcise taxes 8\nF\nForm:\n1099-MISC 8\n1099–NEC 8\n1128 5\n11-C 8\n2290 8\n720 8\n730 8\n8300 9\n8829 11\nI-9 7\nSS-4 4\nW-2 8, 9\nW-4 7\nW-9 4\nForms of business 2\nFUTA tax 7\nG\nGetting a taxpayer identification \nnumber 3\nI\nIncome tax 5, 7\nInformation returns 8\nInventories 5\nL\nLimited liability company 3\nM\nMedicare tax 7\nO\nOffice in home 10\nP\nPartnership 3\nPenalties 9\nPublications (See Tax help)\nR\nRecordkeeping 11\nRecords, how long to keep 16\nS\nS corporation 3\nSelf-employment tax 6\nSocial security tax 7\nSole proprietorship 3\nStart-up costs 9\nT\nTaxes:\nEmployment 7\nEstimated 6\nExcise 8\nHow to deposit 8\nIncome 5\nSelf-employment 6\nUnemployment (FUTA) 7\nTax help 24\nTax year 4\nU\nUnemployment (FUTA) tax 7\nPage 28 \nPublication 583 (January 2021)\n" ]
p4716sp.pdf	1120 Publ 4716 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p4716sp.pdf	[ "Cuando utilice un preparador de impuestos para que \nle ayude a presentar y reclamar el Crédito Tributario \npor Ingreso del Trabajo (EITC, por sus siglas en inglés), \nel Crédito Tributario por Hijos (CTC, por sus siglas en \ninglés) o el Crédito Tributario de Oportunidad para los \nEstadounidenses (AOTC, por sus siglas en inglés), lleve \nestos documentos con usted:\n•\t Licencia de conducir u otra identificación con foto \nválida (si presenta una declaración conjunta, traiga \nuna identificación con foto de su cónyuge y para la \npresentación electrónica ambos cónyuges tienen que \nestar presentes para firmar los formularios)\n•\t Tarjeta de Seguro Social válida o verificación \ndel número de Seguro Social u otro número de \nidentificación tributaria federal para todas las personas \nenumeradas en la declaración de impuestos\n•\t Fechas de nacimiento de todas las personas \nenumeradas en la declaración de impuestos\n•\t Todas las declaraciones de ingresos recibidas, \ntales como salarios, desempleo, compensación no \nlaborable, intereses, dividendos, pensiones, beneficios \nde Seguro Social, venta de acciones u otros ingresos y \ntodo estado que muestre impuestos retenidos\n•\t Si trabaja por cuenta propia, los registros de todos los \ningresos y gastos de negocios\n•\t Registros de los gastos pagados por educación \nsuperior incluidos los Formularios 1098-T, Tuition \nStatement (Declaración de matrícula), en inglés\n•\t Registros de los gastos pagados por el cuidado \nde hijos y dependientes, así como el nombre, \ndirección y número de Seguro Social u otro número \nde identificación tributaria federal del proveedor de \ncuidados\n•\t Número de ruta bancaria y número de cuenta para \ndepositar directamente su reembolso\n•\t Copia de la declaración de impuestos federales del \naño pasado, si está disponible\nPublication 4716 (SP) (11-2020) Catalog Number 75066M Department of the Treasury Internal Revenue Service www.irs.gov\nUn REEMBOLSO de los impuestos federales puede estar esperando por usted\nPrepárese\nSu preparador de impuestos, ya sea remunerado o voluntario, está obligado a hacer preguntas para determinar \nsus ingresos, gastos, deducciones y la cantidad de sus créditos correctos y su elegibilidad para reclamarlos. \nProporcione a su preparador toda la información necesaria y responda todas las preguntas. Un preparador \nremunerado debe firmar su declaración de impuestos y utilizar un número de identificación tributaria del \npreparador.\n" ]
f15247.pdf	1220 Form 15247 (PDF)	https://www.irs.gov/pub/irs-pdf/f15247.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
p5464.pdf	0121 Publ 5464 (PDF)	https://www.irs.gov/pub/irs-pdf/p5464.pdf	[ "Publication 5464 (Rev. 1-2021) Catalog Number 75086E Department of the Treasury \nInternal Revenue Service www.irs.gov \n \n \n \n \nConservation \nEasement \nAudit Technique Guide \n \nThis document is not an official pronouncement of the law or the position of the Service and cannot be \nused, cited, or relied upon as such. This guide is current through the revision date. Since changes may \nhave occurred after the revision date that would affect the accuracy of this document, no guarantees are \nmade concerning the technical accuracy after the revision date. \nThe taxpayer names and addresses shown in this publication are hypothetical. \nAudit Technique Guide Revision Date: 1/21/2021 \n \n \n \n \n \n \n \n \n", "2 \n \nTable of Contents \nI. \nOverview \n.............................................................................................. \n13 \nA. Statement of Purpose \n................................................................... \n13 \nB. Generally \n........................................................................................ \n13 \nC. Background / History \n.................................................................... \n14 \nD. Relevant Terms ............................................................................. \n15 \nD.1. Conservation Easement ..................................................... \n15 \nD.2. Charitable Contribution ...................................................... \n15 \nD.3. Qualified Conservation Contribution ................................ \n15 \nD.4. Conservation Purpose ........................................................ \n16 \nD.5. Fair Market Value \n................................................................. \n16 \nE. Law / Authority .............................................................................. \n16 \nE.1. Exhibit 1-1 Conservation Easement Legal Authority \n....... \n16 \nE.2. Tax Issues \n............................................................................ \n17 \nE.3. Resources \n............................................................................ \n17 \nII. Statutory Requirements for All Charitable Contributions .............. \n18 \nA. Overview ........................................................................................ \n18 \nB. Charitable Contribution Definition .............................................. \n18 \nB.1. Qualified Organization ........................................................ \n18 \nB.2. Charitable Intent \n.................................................................. \n18 \nC. Real Estate Contributions ............................................................ \n18 \nD. Partial Interest Rule ...................................................................... \n19 \n", "3 \n \nE. Conditional Gifts ........................................................................... \n19 \nF. Earmarking .................................................................................... \n19 \nG. Year of Donation ........................................................................... \n19 \nH. Substantiation of Noncash Contributions .................................. \n20 \nI. \nAmount of Deduction ................................................................... \n21 \nIII. Qualified Conservation Contribution \n................................................ \n22 \nA. Overview ........................................................................................ \n22 \nB. Qualified Real Property Interest .................................................. \n22 \nC. Qualified Organization \n.................................................................. \n22 \nD. Conservation Purpose \n.................................................................. \n23 \nE. Perpetuity ...................................................................................... \n23 \nE.1. Reserved Rights \n.................................................................. \n24 \nE.2. Recording Easements \n......................................................... \n25 \nE.3. Amendment Clauses in Easement Deeds \n......................... \n25 \nE.4. Subordination of Mortgages in Lender Agreements \n........ \n26 \nE.5. Extinguishment ................................................................... \n26 \nE.6. Allocation of Proceeds in Deed and Lender Agreements \n26 \nIV. Qualified Organization ....................................................................... \n28 \nA. Overview ........................................................................................ \n28 \nB. Qualified Organization \n.................................................................. \n28 \nC. Commitment and Resources ....................................................... \n28 \nD. Special Rules for Buildings in a Registered Historic District ... \n29 \n", "4 \n \nE. Cash Contributions \n....................................................................... \n29 \nE.1. Quid Pro Quo Contribution ................................................ \n30 \nV. Conservation Purpose ....................................................................... \n30 \nA. Overview ........................................................................................ \n30 \nB. Land for Outdoor Recreation or Education ................................ \n31 \nC. Relatively Natural Habitat or Ecosystem .................................... \n31 \nD. Open Space ................................................................................... \n33 \nD.1. Scenic Enjoyment ............................................................... \n33 \nD.2. Governmental Conservation Policy \n................................... \n34 \nD.3. Significant Public Benefit ................................................... \n34 \nE. Historically Important Land or Structure .................................... \n36 \nE.1. Historically Important Land \n................................................ \n36 \nE.2. Certified Historic Structure ................................................ \n36 \nE.3. Special Rules for Buildings in Registered Historic \nDistricts .................................................................................... \n37 \nF. Public Access \n................................................................................ \n38 \nG. Inconsistent Uses ......................................................................... \n38 \nH. Baseline Study .............................................................................. \n39 \nVI. Substantiation \n..................................................................................... \n39 \nA. Overview ........................................................................................ \n40 \nB. Contemporaneous Written Acknowledgment ............................ \n40 \nC. Form 8283, Noncash Charitable Contributions \n.......................... \n42 \n", "5 \n \nC.1. Generally \n.............................................................................. \n42 \nC.2. Declaration of Appraiser \n..................................................... \n43 \nC.3. Donee Acknowledgment \n..................................................... \n44 \nC.4. Failure to Attach Form 8283 ............................................... \n44 \nD. Qualified Appraisal ....................................................................... \n44 \nD.1. Qualified Appraisal Under Regulations \n............................. \n44 \nD.2. Generally Accepted Appraisal Standards \n......................... \n45 \nD.3. Reasonable Cause .............................................................. \n45 \nE. Façade Easement Filing Fee (Registered Historic District Only)\n \n45 \nF. Baseline Study .............................................................................. \n45 \nG. Additional Donor Recordkeeping Requirements ....................... \n46 \nH. Exhibit 6-1 - Substantiation Requirements \n................................. \n46 \nVII. Qualified Appraisal Requirements \n.................................................... \n47 \nA. Overview ........................................................................................ \n47 \nB. Qualified Appraisal ....................................................................... \n47 \nB.1. Reasonable Cause Exception ............................................ \n49 \nC. Qualified Appraiser \n....................................................................... \n50 \nD. Generally Accepted Appraisal Standards \n................................... \n51 \nD.1. Uniform Standards of Professional Appraisal Practice \n... \n51 \nE. Appraisal Fees .............................................................................. \n53 \nVIII. \nAmount of Deduction ................................................................... \n53 \n", "6 \n \nA. Overview ........................................................................................ \n53 \nB. Percentage Limitations ................................................................ \n53 \nB.1. Individuals \n............................................................................ \n53 \nB.2. Corporations \n........................................................................ \n54 \nB.3. Special Rules for Qualified Farmers and Ranchers \n......... \n54 \nB.4. Carryovers ........................................................................... \n55 \nC. Contributions of Appreciated Property \n....................................... \n55 \nC.1. Ordinary Income and Short-Term Capital Gain Property 55 \nC.2. Long-Term Capital Gain Property \n...................................... \n56 \nD. Bargain Sale .................................................................................. \n57 \nD.1. Taxable Gain \n........................................................................ \n57 \nD.2. Federal and State Easement Purchase Programs ........... \n57 \nE. Quid Pro Quo or Substantial Benefit and Charitable Intent \n...... \n58 \nF. Rehabilitation Tax Credit \n.............................................................. \n58 \nF.1. \nRecapture of Rehabilitation Tax Credit ............................. \n59 \nIX. Valuation of Conservation Easements ............................................. \n59 \nA. Overview ........................................................................................ \n59 \nB. Valuation Process \n......................................................................... \n60 \nC. Valuation Date ............................................................................... \n61 \nD. FMV ................................................................................................ \n61 \nD.1. Before and After Method .................................................... \n61 \n", "7 \n \nD.2. Use of Flat Percentage Cannot Be Applied to Before Value\n \n62 \nD.3. Contiguous Parcels \n............................................................. \n62 \nD.4. Enhancement Rule .............................................................. \n62 \nE. Market Analysis \n............................................................................. \n63 \nF. Highest and Best Use ................................................................... \n64 \nG. Methodology \n.................................................................................. \n65 \nG.1. Sales Comparison Approach ............................................. \n66 \nG.2. Cost Approach \n..................................................................... \n67 \nG.3. Income Capitalization Approach \n........................................ \n67 \nG.4. Subdivision Development Method \n..................................... \n67 \nG.5. Aggregate Partnership Interest \n.......................................... \n69 \nH. Transferable Development Rights \n............................................... \n69 \nX. Partnership Anti-Abuse Rules, Judicial Doctrines, and Codified \nEconomic Substance Doctrine \n.......................................................... \n70 \nA. Partnership Anti-Abuse Rules ..................................................... \n70 \nB. Judicial Doctrines ......................................................................... \n72 \nB.1. Bona Fide Partner and Partnership ................................... \n72 \nB.2. Substance Over Form ......................................................... \n73 \nB.3. Step Transaction Doctrine \n.................................................. \n74 \nC. Codified Economic Substance Doctrine \n..................................... \n76 \nXI. Preplanning the Examination ............................................................ \n77 \nA. Overview ........................................................................................ \n77 \n", "8 \n \nB. Review of Return \n........................................................................... \n77 \nB.1. Form 8283 – Appraisal Summary \n....................................... \n78 \nB.2. Signature Requirements \n..................................................... \n79 \nB.3. Return Attachments ............................................................ \n79 \nB.4. Other Tax Issues ................................................................. \n80 \nB.5. TEFRA Considerations ....................................................... \n80 \nB.6. BBA Considerations (Taxable Years Beginning on or After \nJanuary 1, 2018) ...................................................................... \n81 \nC. Internal Sources of Information \n................................................... \n81 \nC.1. IRS Intranet .......................................................................... \n81 \nC.2. Program Analysts \n................................................................ \n81 \nC.3. Integrated Data Retrieval System – IDRS \n.......................... \n81 \nC.4. Façade Filing Fee Verification \n............................................ \n82 \nC.5. Tax Exempt Organization Search ...................................... \n82 \nC.6. Office of Professional Responsibility \n................................ \n82 \nD. External Sources of Information.................................................. \n83 \nD.1. Internet Research \n................................................................ \n83 \nD.2. Taxpayer............................................................................... \n83 \nD.3. Donee Organization ............................................................ \n83 \nD.4. Appraiser \n.............................................................................. \n84 \nD.5. Public Records .................................................................... \n84 \nD.6. National Park Service \n.......................................................... \n85 \n", "9 \n \nE. Interviews ...................................................................................... \n86 \nF. Information Document Requests \n................................................. \n86 \nG. Valuation Expert Involvement \n...................................................... \n86 \nG.1. Referral to LB&I Engineering ............................................. \n87 \nG.2. Referral Outcomes .............................................................. \n87 \nG.3. LB&I Engineering Products \n................................................ \n88 \nG.4. Outside Experts \n................................................................... \n88 \nH. Consultation with Counsel \n........................................................... \n88 \nI. \nCoordination with TEGE \n............................................................... \n88 \nXII. Conducting the Examination \n............................................................. \n89 \nA. Overview ........................................................................................ \n89 \nB. Interviews ...................................................................................... \n90 \nC. Property Inspection ...................................................................... \n91 \nD. Review of Documents \n................................................................... \n92 \nD.1. Deed of Conservation Easement ....................................... \n92 \nD.2. Perpetuity \n............................................................................. \n93 \nD.3. Conservation Purpose ........................................................ \n93 \nD.4. Reserved Rights \n.................................................................. \n94 \nD.5. Lender Agreements \n............................................................. \n94 \nD.6. Subordination Agreements ................................................ \n94 \nD.7. Allocation of Proceeds ....................................................... \n95 \n", "10 \n \nD.8. Baseline Study \n..................................................................... \n95 \nD.9. Taxpayer’s Appraisal .......................................................... \n97 \nD.10. Donee Organization ............................................................ \n97 \nD.11. Commitment and Resources \n.............................................. \n97 \nD.12. Cash Payments \n.................................................................... \n98 \nD.13. Contemporaneous Written Acknowledgment................... \n99 \nD.14. National Park Service – Form 10-168 ................................ \n99 \nD.15. Partnership Documents \n.................................................... \n101 \nE. Third-Party Contacts .................................................................. \n101 \nE.1. Donee Organizations ........................................................ \n102 \nE.2. Mortgage Lenders ............................................................. \n102 \nE.3. Appraiser \n............................................................................ \n103 \nE.4. Federal and State Conservation Agencies ..................... \n103 \nE.5. Local Government Officials \n.............................................. \n103 \nE.6. Real Estate Agents \n............................................................ \n104 \nE.7. Property Owners ............................................................... \n104 \nXIII. \nConcluding the Examination...................................................... \n104 \nA. Overview ...................................................................................... \n104 \nB. Issue Identification ..................................................................... \n105 \nB.1. Substantial Compliance \n.................................................... \n105 \nC. Report Writing ............................................................................. \n106 \n", "11 \n \nC.1. Job Aids ............................................................................. \n107 \nC.2. Valuation Expert Reports ................................................. \n108 \nC.3. Penalties............................................................................. \n108 \nC.4. Technical Assistance \n........................................................ \n109 \nD. Closing Conference .................................................................... \n109 \nE. Taxpayer Protests \n....................................................................... \n109 \nE.1. Rebuttals to Taxpayer Protest ......................................... \n109 \nF. Exhibit 13-1 Conservation Easement Issue Identification \nWorksheet \n.................................................................................... \n110 \nXIV. \nPenalties ...................................................................................... \n114 \nA. Overview ...................................................................................... \n114 \nB. Introduction to Penalty Approval .............................................. \n115 \nC. Accuracy-Related Penalties \n....................................................... \n117 \nC.1. Section 6662(b)(1) and (c) Negligence or Disregard of \nRules or Regulations \n............................................................. \n117 \nC.2. Section 6662(b)(2) and (d) Substantial Understatement of \nIncome Tax \n............................................................................. \n118 \nC.3. Section 6662(b)(3) and (e) Substantial Valuation \nMisstatement and Section 6662(h) Gross Valuation \nMisstatement ......................................................................... \n118 \nC.4. Section 6662(b)(6) and (i) Codified Economic Substance \nDoctrine \n.................................................................................. \n119 \nD. Section 6663 Civil Fraud Penalty \n............................................... \n120 \nE. Section 6664 Reasonable Cause Exception \n............................. \n120 \n", "12 \n \nE.1. Special Rule for Overvaluation of Charitable \nContributions \n......................................................................... \n120 \nE.2. Reliance on Professionals \n................................................ \n121 \nF. Section 6694 Understatement of Taxpayer’s Liability by Tax \nReturn Preparer \n........................................................................... \n122 \nG. Sections 6700 and 6701 Penalty for Promoting Abusive Tax \nShelters and Aiding and Abetting Understatements of Tax ... \n122 \nH. Section 6695A Substantial and Gross Valuation Misstatements \nAttributable to Incorrect Appraisals \n.......................................... \n123 \nH.1. Office of Professional Responsibility Sanctions............ \n124 \nI. \nPenalties Specifically Related to Reportable Transactions .... \n124 \nI.1. Section 6662A Accuracy-Related Penalty on \nUnderstatements with Respect to Reportable Transactions\n \n125 \nI.2. Section 6707A Penalty for Failure to Include Reportable \nTransaction Information with Return \n................................... \n126 \nI.3. Section 6707 Failure to Furnish Information Regarding \nReportable Transaction ........................................................ \n126 \nI.4. Section 6708 Failure to Maintain Lists of Advisees with \nRespect to Reportable Transactions ................................... \n127 \nXV. \nState Tax Credits \n......................................................................... \n127 \nA. Overview ...................................................................................... \n127 \nB. State Tax Credit Programs \n......................................................... \n127 \nC. Receipt of State Tax Credits ...................................................... \n128 \nD. Sale of State Tax Credits \n............................................................ \n129 \n \n", "13 \n \nI. Overview \nA. Statement of Purpose \n(1) The purpose of this audit techniques guide (ATG) is to provide guidance for the \nexamination of charitable contributions of conservation easements. Users of \nthis guide will learn about the general requirements for charitable contributions \nand additional requirements for contributions of conservation easements. \n(2) This ATG includes examination techniques and an overview of the valuation of \nconservation easements. It also includes a discussion of penalties, which may \nbe applicable to taxpayers and others involved in the conservation easement \ntransaction. \n(3) This guide is not designed to be all-inclusive. It is not a comprehensive training \nmanual for conservation easements. \nB. Generally \n(1) To be deductible, donated conservation easements must be legally binding, \npermanent restrictions on the use, modification and development of property \nsuch as farmland, forest land, scenic areas, historic land or historic structures. \nThe restrictions on the property must be in perpetuity. Current and future \nowners of the easement and the underlying property must all be bound by the \nterms of the conservation easement deed. \n(2) The general rule is that no charitable contribution deduction is allowed for a \ntransfer of property of less than the taxpayer’s entire interest in the property. \nIRC § 170(f)(3). Section 170(f)(3)(B)(iii) provides an exception to the partial \ninterest rule for qualified conservation contributions. \n(3) Section 170(h)(1) of the Internal Revenue Code (IRC) states that a qualified \nconservation contribution is a contribution of a qualified real property interest \n(i.e., a restriction granted in perpetuity on the use which may be made of the \nreal property) to a qualified organization exclusively for conservation purposes. \nThe IRC and accompanying Treasury Regulations outline the requirements that \nmust be met before a charitable contribution is deductible. \n(4) Qualified organizations that accept conservation easements must have a \ncommitment to protect the conservation purposes of the donation in perpetuity \nand must have sufficient resources to enforce compliance with the terms of the \neasement deed. \n(5) Section 170(h)(4)(A) specifies the four conservation purposes: \n• Preservation of land areas for outdoor recreation by, or the education of, \nthe general public. \n• Protection of a relatively natural habitat of fish, wildlife, or plants, or similar \necosystem. \n", "14 \n \n• Preservation of open space (including farmland and forest land), where \nsuch preservation is for the scenic enjoyment of the general public or \npursuant to a clearly delineated federal, state, or local governmental \nconservation policy and, for both purposes, will yield a significant public \nbenefit. \n• Preservation of a historically important land area or a certified historic \nstructure. \n(6) The donation of a conservation easement that meets all statutory and \nregulatory requirements, including specific substantiation requirements, can be \nclaimed as a charitable contribution deduction. \n(7) The value of a conservation easement must be determined in a qualified \nappraisal prepared and signed by a qualified appraiser. The value of the \ncontribution is the fair market value (FMV) of the conservation easement at the \ntime of the contribution. To the extent there is a substantial record of sales of \nconservation easements comparable to the donated easement, the FMV is \nbased on the sales price of such comparables. If there is no substantial record \nof marketplace sales, the value is generally the difference between the FMV of \nthe underlying property before and after the easement is granted to the donee. \nBecause there is usually no substantial record of comparable sales, a before \nand after valuation is used in most cases. \n(8) To conduct a quality examination, in-depth development of facts is necessary. \nExaminers have primary responsibility for addressing the taxpayer’s compliance \nwith all statutory and regulatory requirements. \n(9) Valuation is also an important component of this tax issue. A multi-divisional \napproach, working with LB&I Engineering, Counsel, and Tax Exempt and \nGovernment Entities (TEGE), may be needed to properly develop tax issues in \na conservation easement examination. \n(10) \nTaxpayers, return preparers, appraisers, and others involved with an improper \nor overvalued conservation easement may be subject to various penalties. \n(11) \nWhile the charitable contribution of a conservation easement may be the most \nsignificant issue on the tax return, Examiners should be alert to other related tax \nissues such as a sale of state tax credits, basis adjustments, or a recapture of \nrehabilitation tax credits. \nC. Background / History \n(1) In recognition of our need to preserve our heritage, Congress allowed an \nincome tax deduction for owners of significant property who give up certain \nrights of ownership to preserve their land or buildings for future generations. \n(2) The IRS has seen abuses of this tax provision that compromise the policy \nCongress intended to promote. We have seen taxpayers, often encouraged by \npromoters and armed with questionable appraisals, take inappropriately large \n", "15 \n \ndeductions for easements. In some cases, taxpayers claim deductions when \nthey are not entitled to any deduction at all (for example, when taxpayers fail to \ncomply with the law and regulations governing deductions for contributions of \nconservation easements). Also, taxpayers have sometimes used or developed \nthese properties in a manner inconsistent with section 501(c)(3). In other cases, \nthe charity has allowed property owners to modify the easement or develop the \nland in a manner inconsistent with the easement’s restrictions. \n(3) Another problem arises in connection with historic easements, particularly \nfaçade easements. Here again, some taxpayers are taking improperly large \ndeductions. They agree not to modify the façade of their historic house and they \ngive an easement to this effect to a charity. However, if the façade was already \nsubject to restrictions under local zoning ordinances, the taxpayers may, in fact, \nbe giving up nothing, or very little. A taxpayer cannot give up a right that he or \nshe does not have. \nD. Relevant Terms \nD.1. Conservation Easement \n(1) “Conservation easement” is the generic term for easements granted for \npreservation of land areas for outdoor recreation, protection of a relatively \nnatural habitat for fish, wildlife, or plants, or a similar ecosystem, preservation of \nopen space for the scenic enjoyment of the public or pursuant to a federal, \nstate, or local governmental conservation policy, and preservation of a \nhistorically important land area or historic building. \n(2) Conservation easements permanently restrict how land or buildings are used. \nThe “deed of conservation easement” describes the conservation purpose, the \nrestrictions and the permissible uses of the property. The deed must be \nrecorded in the public record and must contain legally binding restrictions \nenforceable by the donee organization. \n(3) The donor gives up certain rights specified in the deed of conservation \neasement, but retains ownership of the underlying property. The extent and \nnature of the donee organization’s control depends on the terms of the \nconservation easement deed. The organization has an interest in the \nencumbered property that runs with the land, which means that its restrictions \nare binding not only on the landowner who grants the easement but also on all \nfuture owners of the property. \nD.2. Charitable Contribution \n(1) A charitable contribution is a contribution or gift to or for the use of a qualifying \norganization. See Chapter 2. \nD.3. Qualified Conservation Contribution \n", "16 \n \n(1) Section 170(h)(1) defines a qualified conservation contribution as a contribution \nof a qualified real property interest to a qualified organization to be used \nexclusively for conservation purposes. \nD.4. Conservation Purpose \n(1) Section 170(h)(4)(A) defines “conservation purpose” as one of the following: \n• Preservation of land for outdoor recreation by, or the education of, the \ngeneral public. \n• Protection of a relatively natural habitat of fish, wildlife, or plants, or similar \necosystem. \n• Preservation of open space (including farmland and forest land) either for \nthe scenic enjoyment of the general public or pursuant to a clearly \ndelineated governmental conservation policy (both purposes must yield a \nsignificant public benefit). \n• Preservation of a historically important land area or a certified historic \nstructure. \n(2) The easement must be created by deed and be exclusively for conservation \npurposes. Donations of conservation easements may meet more than one \nconservation purpose. \nD.5. Fair Market Value \n(1) The value of the donated easement must meet the definition of FMV as defined \nby Treas. Reg. § 1.170A-1(c)(2): The FMV is the price at which the property \nwould change hands between a willing buyer and a willing seller, neither being \nunder any compulsion to buy or sell and both having reasonable knowledge of \nrelevant facts. \nE. Law / Authority \nE.1. Exhibit 1-1 Conservation Easement Legal Authority \n(1) NOTE: This exhibit is not an all-inclusive list of potential issues for donations of \nconservation easements. Users should review IRC § 170, DEFRA § 155, the \ncorresponding Treasury Regulations, Notice 2006-96 and case law. \n \nCode/Regs/Other \nTitle \n IRC § 170 \nCharitable, etc., contributions and gifts \n DEFRA § 155 \nDeficit Reduction Act of 1984 \n Notice 2006-96 \nGuidance Regarding Appraisal \nRequirements for Noncash Charitable \n", "17 \n \nContributions \n Treas. Reg. § 1.170A-1 \nCharitable, etc., contributions and gifts; \nallowance of deduction \n Treas. Reg. § 1.170A-13 \nRecordkeeping and return requirements for \ndeductions for charitable contributions \n Treas. Reg. § 1.170A-14 \nQualified conservation contributions \n Treas. Reg. § 1.170A-16 \nSubstantiation and reporting requirements \nfor noncash charitable contributions \n Treas. Reg. § 1.170A-17 \nQualified appraisal and qualified appraiser \n \nE.2. Tax Issues \n(1) Taxpayers must satisfy numerous statutory provisions in order to claim a \nnoncash charitable contribution deduction for the donation of a conservation \neasement. Some deficiencies revealed in examinations of conservation \neasements include: \n• Failure to meet charitable contributions rules, for example the easement \nwas granted in exchange for a change in zoning by the county (a quid pro \nquo). \n• Noncompliance with substantiation requirements. \n• Inadequate documentation of or lack of conservation purpose. \n• Lack of perpetuity evidenced by terms in the deeds. \n• Reserved property rights inconsistent with conservation purpose. \n• Failure to comply with subordination rules. \n• Failure to provide the donee organization with the specified proportionate \nshare of the proceeds in the event of extinguishment. \n• Use of improper appraisal methodologies. \n• Failure to report income from the sale of state tax credits. \n• Overvalued conservation easements. \n(2) The IRS has identified some promoters and appraisers involved in conservation \neasement tax schemes. \nE.3. Resources \n(1) Information about conservation easements, including contacts, job aids, and \nother reference materials are on the IRS Virtual Library, Form 1040 Knowledge \nBase. \n", "18 \n \nII. Statutory Requirements for All Charitable Contributions \nA. Overview \n(1) In order to claim a charitable contribution deduction for a conservation \neasement, taxpayers must meet the statutory requirements applicable to all \ncharitable contributions, as well as the specific requirements for conservation \neasement donations. \n(2) See Publication 526, Charitable Contributions (PDF), Publication 561, \nDetermining the Value of Donated Property (PDF), and Publication 1771, \nCharitable Contributions - Substantiation and Disclosure Requirements (PDF). \nB. Charitable Contribution Definition \n(1) A charitable contribution is a contribution or gift to or for the use of a qualifying \norganization. It is a transfer of money or property made with charitable intent \nand without receipt of adequate consideration. IRC § 170(c); Treas. Reg. § \n1.170A-1(h). \n(2) Section 170 contains the rules that govern income tax deductions for charitable \ncontributions, including donations of conservation easements. \nB.1. Qualified Organization \n(1) A taxpayer can only deduct contributions made to organizations eligible to \naccept tax-deductible contributions, which are organizations described in IRC § \n170(c). \n(2) An organization accepting tax-deductible contributions of conservation \neasements must meet additional requirements to be a qualified organization. \nSee Chapter 4 for additional guidance on qualified organizations. \nB.2. Charitable Intent \n(1) A charitable contribution is a donation or gift to, or for the use of, a qualified \norganization. It is voluntary and made without receipt, or the expectation of \nreceipt, of anything of economic value. \n(2) A transfer of money or property is not voluntary if it is required or is made with \nthe expectation of a direct or indirect benefit. A benefit received or expected to \nbe received in connection with a payment or transfer by the taxpayer is called a \nquid pro quo. \n(3) See Chapter 8 for additional discussion of charitable intent and quid pro quo. \nC. Real Estate Contributions \n(1) For a contribution of real estate, including a contribution of a conservation \neasement, there is no “transfer,” and therefore no deductible charitable \ncontribution, unless there is: \n", "19 \n \n• A deed signed by the donor transferring the property and \n• Acceptance by the qualified organization. \n(2) Conservation easement deeds must be recorded in the public record. \nD. Partial Interest Rule \n(1) Generally, in order to have a deductible contribution, a taxpayer must contribute \nthe entire interest in the property. A partial interest is generally not deductible. \nThis is known as the \"partial interest\" rule. IRC § 170(f)(3)(A). \n(2) A qualified conservation contribution is deductible even though it is a partial \ninterest. It is an exception to the partial interest rule. IRC §§ 170(f)(3)(B)(iii) and \n(h). \nE. Conditional Gifts \n(1) If the contribution is a conditional gift, the donor cannot take a deduction. \n• Example: If Justin transfers land in Maine to a city on the condition that \nthe land is used by the city for an unlikely use (e.g., alligator habitat), there \nis no deductible charitable contribution before the time that the specified \nuse actually occurs. \n(2) However, if there is only a negligible chance that the gift will be defeated, the \ndeduction is allowed. Treas. Reg. §§ 1.170A-1(e) and 1.170A-7(a)(3). \n• Example: Susan transfers land to a city on the condition that the land is \nused by the city for a public park. If, on the date of the gift, the city plans to \nuse the property as a park, and the possibility that it will not be used as a \npark is so remote as to be negligible, the deduction is allowable at the time \nof the transfer to the city. \nF. Earmarking \n(1) A taxpayer may not deduct earmarked contributions (e.g., for the benefit of a \nparticular individual or family). Earmarked amounts are treated as transfers to \nthe earmarked beneficiary and not as transfers to the IRC § 170(c) \norganization. \n• Example: Steven made payments to his church. He earmarked the \npayments for John, a needy individual. Steven cannot deduct the amount \nof the payments since he earmarked the funds for John. The church was \nmerely a conduit for Steven’s gift to John. \nG. Year of Donation \n(1) A taxpayer may deduct contributions paid within the taxable year. IRC § \n170(a)(1) and Treas. Reg. § 1.170A-1(a) and (b). \n", "20 \n \n(2) A promise to pay cash or transfer property in the future is not deductible. The \ntaxpayer may deduct payments made by check when the check is mailed or \ndelivered to the IRC § 170(c) organization. Treas. Reg. § 1.170A-1(b). \n(3) For conservation easements, the year of the deduction is the year of \nrecordation. Treas. Reg. § 1.170A-14(g)(1). \n• Example: A conservation easement was granted to a qualified \norganization on December 20, 2007, as evidenced by the dated \nsignatures on the conservation easement deed. However, the easement \nwas not recorded in the public records until March 12, 2008. The year of \ndonation is 2008. \nH. Substantiation of Noncash Contributions \n(1) A charitable contribution is not deductible unless it is properly substantiated in \naccordance with the IRC and the regulations. The documentation requirements \nvary depending on the date of contribution, nature of the contribution (noncash \nin the case of a conservation easement), type of property contributed, and \ndollar amount claimed. For a conservation easement, the following documents \nare required: \n(2) Contemporaneous written acknowledgment from the donee organization. IRC § \n170(f)(8). The contemporaneous written acknowledgment must meet the \nacknowledgment requirement and the contemporaneous requirement. \n• The acknowledgment must: \n• Be in writing, \n• Describe the property received by the donee, \n• Contain a statement of whether the donee provided any goods or \nservices in consideration, in whole or in part, for the gift, and \n• Provide a description of and a good faith estimate of the goods or \nservices, other than intangible religious benefits, provided to the \ntaxpayer. \n• The contemporaneous requirement provides: \n• The taxpayer must get the acknowledgment on or before the earlier \nof: \n• The date the taxpayer files a return for the year in which the \ncontribution was made, or \n• The due date (including extensions) for filing such return. \n(3) Form 8283, Section B, with supplemental statement. \n(4) Deed (should be stamped with the recording date). \n(5) Qualified Appraisal (for contributions of more than $5,000). \n", "21 \n \n(6) Baseline study. \n(7) The tax court has considered a number of cases in which taxpayers argued that \nthe deed of easement satisfied the contemporaneous written acknowledgment \nrequirement. In French v. Commissioner, T.C. Memo. 2016-53, and Schrimsher \nv. Commissioner, T.C. Memo. 2011–71, the deed did not satisfy the \ncontemporaneous written acknowledgment requirement. In Big River \nDevelopment, LP v. Commissioner, T.C. Memo. 2017-166; 310 Retail, LLC v. \nCommissioner, T.C. Memo. 2017-164; RP Golf, LLC v. Commissioner, T.C. \nMemo. 2012-282; and Averyt v. Commissioner, T.C. Memo. 2012–198, the \ndeed did satisfy the contemporaneous written acknowledgment requirement. \n(8) Examiners should contact Counsel for assistance if a taxpayer contends that \nthe deed of easement satisfies the contemporaneous written acknowledgment \nrequirement. \n(9) In Belair Woods, LLC v. Commissioner, T.C. Memo. 2018-159, a Form 8283 \nthat omitted the cost basis of the subject property, with an attachment indicating \nthat it was not necessary to disclose it, neither strictly nor substantially complied \nwith the regulatory requirement to include such information on the form. See \nalso RERI Holdings v. Commissioner, 149 T.C. 1 (2017); Treas. Reg. § 1.170A-\n13(c)(2)(i)(B) and (4)(ii)(E). Taxpayers are afforded the opportunity to \ndemonstrate reasonable cause for omitting the information. IRC § \n170(f)(11)(A)(ii)(II). \n(10) \nSee Publication 526, Charitable Contributions (PDF), and Publication 1771, \nCharitable Contributions - Substantiation and Disclosure Requirements (PDF) \nand Chapter 6 for additional guidance on substantiation requirements. \n(11) \nSee IRC § 170(f)(8)(A)-(D), Treas. Reg. § 1.170A-13(f) (effective for \ncontributions made on or after December 16, 1996 and on or before July 30, \n2018) and Treas. Reg. § 1.170A-16(a) (effective for contributions made after \nJuly 30, 2018). \n(12) \nSee also Section 155 of the Deficit Reduction Act of 1984 (DEFRA), Pub. L. 98-\n369, 98 Stat. 691, Treas. Reg. § 1.170A-13(c)(2)(i)(B) (effective for contribution \nmade after December 31,1984, and on or before July 30, 2018) and Treas. \nReg. § 1.170A-16(c)-(e) (effective for contributions made after July 30, 2018). \nI. Amount of Deduction \n(1) Factors that may affect the amount a taxpayer may claim as a charitable \ncontribution deduction for a conservation easement include: \n• FMV \n• Quid pro quo and charitable intent \n• Bargain sale \n", "22 \n \n• Type of property (ordinary income, short-term capital gain, long-term \ncapital gain) \n• Basis \n• Percentage limitations \n• Type of donee organization \n(2) See Chapter 8 and Publication 526, Charitable Contributions (PDF) for \nadditional guidance on specific limitations on charitable contributions. \nIII. Qualified Conservation Contribution \nA. Overview \n(1) Section 170(h)(1) defines a qualified conservation contribution as a contribution \nof a qualified real property interest to a qualified organization to be used \nexclusively for conservation purposes. \nB. Qualified Real Property Interest \n(1) A qualified real property interest is any of the following interests in real property: \n• The entire interest of the donor, other than a qualified mineral interest. \n• A remainder interest. \n• A restriction on the use of the real property granted in perpetuity (often \nreferred to as a conservation easement). \n(2) See IRC § 170(h)(2). \nC. Qualified Organization \n(1) The recipient of a deductible conservation easement donation must be a \nqualified organization and also an eligible donee. IRC §§ 170(h)(1)(B) and \n170(h)(3); Treas. Reg. § 1.170A-14(c)(1). \n(2) Qualified organizations include: \n• The federal government, a United States (U.S.) possession, the District of \nColumbia, a state government, or any political subdivision of a state or \nU.S. possession. \n• An organization described in IRC § 170(b)(1)(A)(vi). \n• A charity described in IRC § 501(c)(3) that meets the public support test of \nIRC § 509(a)(2). \n• An IRC § 501(c)(3) organization that meets the requirements of IRC § \n509(a)(3) and is controlled by one of the organizations described above. \n(3) Note: See Treas. Reg. § 1.170A-14(c)(1) for the requirements to qualify as an \neligible donee. \n", "23 \n \n(4) See IRC § 170(h)(3) and Chapter 4 for additional information on qualified \norganizations. \nD. Conservation Purpose \n(1) Section 170(h)(4)(A) defines “conservation purpose” as one of the following: \n• Preservation of land for outdoor recreation by, or the education of, the \ngeneral public. \n• Protection of a relatively natural habitat of fish, wildlife, or plants, or similar \necosystem. \n• Preservation of open space (including farmland and forest land) either for \nthe scenic enjoyment of the general public or pursuant to a clearly \ndelineated governmental conservation policy (both purposes must yield a \nsignificant public benefit). \n• Preservation of a historically important land area or a certified historic \nstructure. \n(2) The easement must be created by deed and be exclusively for conservation \npurposes. Donations of conservation easements may meet more than one \nconservation purpose. \n(3) See Chapter 5 for additional information on conservation purpose. \nE. Perpetuity \n(1) A deductible conservation easement must be made in perpetuity, permanently \nrestricting the use of the property. Section 170(h)(2)(C) requires that the interest \nin real property be subject to a use restriction granted in perpetuity, and IRC § \n170(h)(5)(A) requires that the conservation purpose be protected in perpetuity. \nSee also Treas. Reg. §§ 1.170A-14(b)(2) and 1.170A-14(g)(1). \n(2) This means that the deed of conservation easement must indicate that the \nrestriction remains on the property forever and is binding on current and future \nowners of the property. \n(3) If a deed of conservation easement does not meet the perpetuity requirements, \nthe contribution of a conservation easement is not deductible. \n(4) If the conservation easement deed imposes restrictions for a specific period \nsuch as ten years, it is not in perpetuity and is not deductible. An easement is \nnot enforceable in perpetuity if it ends after a period of years or if it can revert to \nthe donor or to another private party. However, if a remote future event, like an \nearthquake, can extinguish the easement, the donation could nevertheless be \ntreated as enforceable in perpetuity. Treas. Reg. § 1.170A-14(g)(3). \n(5) In Carpenter v. Commissioner, T.C. Memo. 2012-1, a conservation easement \nwas not enforceable in perpetuity because it allowed for the extinguishment of \nthe easement by mutual consent of the parties if circumstances arose in the \n", "24 \n \nfuture that would render the purpose of the conservation easement impossible \nto accomplish. \n(6) In Belk v. Commissioner, 140 T.C. 1 (2013), motion for reconsideration denied, \nT.C. Memo. 2013-154, aff’d 774 F.3d 1243 (4th Cir. 2014), the deed of \neasement allowed the taxpayers and donee to change the property subject to \nthe easement by substituting other property owned by the taxpayers for the \nproperty originally subject to the easement. The tax court ruled that the \nprovision caused the easement to fail the requirements of IRC § 170(h)(2)(C), \nas the donated property interest was not subject to a use restriction granted in \nperpetuity. \n(7) In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 247 (2018), and \nPine Mountain Preserve, LLLP v. Commissioner, 116 T.C. Memo. 214, rev’d in \npart, aff’d in part, vacated and remanded, 2020 WL 6193897 (11th Cir. Oct. 22, \n2020), the 2005 deed of easement set out boundaries for ten building areas, but \nallowed the boundaries to be modified by mutual agreement of the donor and \nNALT, the donee. The 2006 deed of easement allowed the designation of six \nbuilding areas within the conservation area, but with no other restriction on \nlocation except that the locations must be approved in advance by NALT. The \ntax court, following Belk, ruled that these provisions caused the easement to fail \nthe grant in perpetuity requirements of IRC § 170(h)(2)(C). In so doing, the \ncourt explicitly rejected the holding in BC Ranch II, L.P. v. Commissioner, 867 \nF.3d 547 (5th Cir. 2017), where the Fifth Circuit ruled that the so-called floating \nhomesites did not defeat perpetuity. The Eleventh Circuit, in Pine Mountain, \nruled that the moveable building areas do not violate the “granted in perpetuity” \nrequirement under § 170(h)(2)(C), but remanded the issue of whether they \nviolate the “protected in perpetuity” requirement under § 170(h)(5)(A). The \nEleventh Circuit agreed with the tax court that the amendment clause did not \nviolate the protected in perpetuity requirement of IRC § 170(h)(5)(A). Lastly, the \nEleventh Circuit held that when determining the fair market value of the \neasement, the tax court should value the easement using the standards set \nforth in the governing regulations. \n(8) Agents should note that under Golsen v. Commissioner, 54 T.C. 742, 756-57, \naff’d, 445 F.2d 985 (10th Cir. 1971), the tax court is bound by an appellate \ncourt’s opinions in cases appealable to that appellate court’s circuit. We \nrecommend that all floating homesite/moveable building area clause cases and \namendment clause cases be referred to the assigned LB&I and SB/SE \nCounsel. \nE.1. Reserved Rights \n(1) In Hoffman Props. II, LP v. Commissioner, 956 F.3d 832 (6th Cir. 2020), a \nfaçade easement case, the Sixth Circuit Court of Appeals affirmed the tax \ncourt’s holding that the automatic approval clause in the deed rendered the \neasement nondeductible because the clause was inconsistent with the \neasement being enforceable in perpetuity under IRC § 170(h)(5)(A). The clause \n", "25 \n \nreserved to the donor rights to modify the building façade if the donor obtained \nthe prior approval of the easement holder, but if the holder failed to respond to a \nrequest for approval within 45 days, the request was automatically considered \napproved. The court of appeals explained that a failure of the donee to act \nwithin 45 days would foreclose its ability to prevent the proposed modification. \nFor a CCA containing an acceptable “constructive denial” clause, see CCA \n202002011 (released Jan. 10, 2020). \nE.2. Recording Easements \n(1) The deed of conservation easement must be recorded in the appropriate \nrecordation office. See generally Treas. Reg. § 1.170A-14(g)(1). \n(2) In a federal tax controversy, state law controls the determination of a taxpayer’s \ninterest in property while the tax consequences are determined under federal \nlaw. United States v. Nat’l Bank of Commerce, 472 U.S. 713, 722 (1985); \nWoods v. Commissioner, 137 T.C. 159, 162 (2011). An easement is not \nenforceable in perpetuity before it is recorded. \n(3) In addition to the deed, all exhibits or attachments to the deed, such as a \ndescription of the easement restrictions, maps, and lender agreements, may \nneed to be recorded. In Herman v. Commissioner, T.C. Memo. 2009-205, the \ntaxpayer recorded a “Declaration of Restrictive Covenant” for a donation of \nunused development rights above a building in New York City. The covenant \nreferred to an attached architectural drawing, which described the easement \nrestrictions, but the drawing was not recorded. The court ruled that because the \nattached drawing was not recorded, it could not bind subsequent purchasers, \ndid not protect the conservation purpose of preserving the building “in \nperpetuity,” and failed to meet the requirements of IRC § 170(h)(5)(A). But see \nButler v. Commissioner, T.C. Memo. 2012-72, holding that documents \nincorporated into the deed by reference do not have to be recorded with the \ndeed under Georgia law. \nE.3. Amendment Clauses in Easement Deeds \n(1) The restriction on the use of the real property must be enforceable in perpetuity, \nmeaning that it lasts forever and binds all future owners. An easement deed \nmay fail the perpetuity requirements of IRC § 170(h)(2)(C) and (h)(5)(A) if it \nallows any amendment or modification that could adversely affect the perpetual \nduration of the deed restriction. \n(2) In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 247 (2018), rev’d \nin part, aff’d in part, vacated and remanded, 2020 WL 6193897 (11th Cir. Oct. \n22, 2020), the deed of easement allowed the donor and the donee to amend \nthe deed by agreement so long as the amendment was not inconsistent with the \nconservation purposes. The tax court ruled that such an amendment clause \ndoes not violate the enforceable in perpetuity requirements of IRC § \n", "26 \n \n170(h)(5)(A). See discussion of amendment clauses and the Pine Mountain \ncase above under the heading “Perpetuity.” \n(3) The issue of Amendment Clauses is different than the issue of Reserved \nRights. See Chapter 12 for information on Reserved Rights in an easement \ndeed. \nE.4. Subordination of Mortgages in Lender Agreements \n(1) If the property has a mortgage or lien in effect at the time the easement is \nrecorded, the easement contribution is not deductible unless the mortgagee or \nlien holder subordinates its rights in the property to the rights of the donee \norganization to enforce the conservation purposes of the easement in \nperpetuity. Treas. Reg. § 1.170A-14(g)(2). \n(2) The subordination agreement must be recorded in a timely manner. \n(3) In Minnick v. Commissioner, T.C. Memo. 2012‐345, aff’d, 796 F.3d 1156 (9th \nCir. 2015), the tax court held that petitioners were not entitled to a charitable \ncontribution deduction because they failed to meet the subordination \nrequirements (i.e., the mortgagor and petitioners had not entered into a \nsubordination agreement at the time the easement was donated, rather, it was \nentered into after the donation). See also Mitchell v. Commissioner, 138 T.C. \n324 (2012), supplemented by T.C. Memo. 2013-204, aff’d, 775 F.3d 1243 (10th \nCir. 2015); RP Golf, LLC v. Commissioner, T.C. Memo. 2016‐80, aff’d 860 \nF.3d1096 (8th Cir. 2018); Palmolive Building Investors v. Commissioner, 149 \nT.C. 380 (2017). \nE.5. Extinguishment \n(1) Treas. Reg. § 1.170A-14(g)(6)(i) generally provides that if a subsequent \nunexpected change in the conditions surrounding the property that is the \nsubject of a donation can make impossible or impractical the continued use of \nthe property for conservation purposes, the conservation purpose can \nnonetheless be treated as protected in perpetuity if the restrictions are \nextinguished by judicial proceeding and all of the donee’s proceeds (determined \nunder Treas. Reg. § 1.170A-14(g)(6)(ii)) from a subsequent sale or exchange of \nthe property are used by the donee organization in a manner consistent with the \nconservation purposes of the original contribution. \nE.6. Allocation of Proceeds in Deed and Lender Agreements \n(1) In order to claim a charitable contribution deduction for the donation of a \nconservation easement, the donor, at the time of the gift, must agree that the \ndonation of the perpetual conservation restriction gives rise to a property right, \nimmediately vested in the donee organization, with a FMV that is at least equal \nto the proportionate value that the perpetual conservation restriction at the time \nof the gift bears to the value of the property as a whole. The proportionate value \n", "27 \n \nof the donee’s property rights must remain constant. The donee organization \nmust be entitled to a portion of the proceeds at least equal to that proportionate \nvalue of the perpetual conservation restriction. The requirements of Treas. Reg. \n§ 1.170A-14(g)(6)(i) and (ii) are strictly construed. If a grantee is not absolutely \nentitled to the proportionate share of extinguishment proceeds, then the \nconservation purpose of the contribution is not protected in perpetuity. The only \nexception is if state law provides that the donor is entitled to the full proceeds \nfrom the conversion without regard to the terms of the prior perpetual \nconservation restriction. Treas. Reg. § 1.170A-14(g)(6)(ii) (last clause). \n(2) Treas. Reg. § 1.170A-14(g)(6)(ii) requires the donee’s proportionate interest \nupon extinguishment of a conservation easement to be a percentage \ndetermined by (1) the FMV of the conservation easement on the date of the gift \n(numerator), over (2) the FMV of the property as a whole on the date of the gift \n(denominator). \n(3) In Carroll v. Commissioner, 146 T.C. 196 (2016), petitioners’ deed of \nconservation easement instead used a ratio of the charitable contribution \ndeduction allowable over the value of the property as a whole on the date of the \ngift. Thus, the deed failed to satisfy Treas. Reg. § 1.170A- 14(g)(6)(ii) because it \ndid not guarantee the donee a proportionate share of the extinguishment \nproceeds based on the FMV of the conservation easement at the time of the \ngift. \n(4) In PBBM-Rose Hill, Ltd. v. Commissioner, 900 F.3d 193 (5th Cir. 2018), the \ndeed of easement provided that in case of extinguishment, the donee would \nreceive the proportionate value required by the regulation less the expenses of \nthe sale and the amount attributable to improvements constructed after the \neasement. The court disallowed the deduction because any reduction to the \nproportionate value required by the regulation failed to satisfy its requirements. \n(5) In Coal Property Holdings, LLC v. Commissioner, 153 T.C. 126 (2019), the \ndeed of easement provided that in case of extinguishment, the donee would \nreceive the proportionate value required by the regulation “after the satisfaction \nof prior claims” and less any increase in value attributable to improvements. \nThe court, following PBBM-Rose Hill, disallowed the deduction because any \nreduction to the proportionate value required by the regulation failed to satisfy \nits requirements. \n(6) See also Plateau Holdings, LLC v. Commissioner, T.C. Memo. 2020-93; Belair \nWoods, LLC v. Commissioner, T.C. Memo. 2020-112; Village at Effingham, LLC \nv. Commissioner, T.C. Memo. 2020-102; Riverside Place, LLC v. \nCommissioner, T.C. Memo. 2020-103; Maple Landing, LLC v. Commissioner, \nT.C. Memo. 2020-104; Englewood Place, LLC v. Commissioner, T.C. Memo. \n2020-105; Hewitt v. Commissioner, T.C. Memo. 2020-89; Woodland Property \nHoldings, LLC v. Commissioner, T.C. Memo. 2020-55; Oakbrook Land \nHoldings, LLC v. Commissioner, T.C. Memo. 2020-54; Cottonwood Place, LLC \nv. Commissioner, T.C. Memo. 2020-115; Red Oak Estates, LLC v. \n", "28 \n \nCommissioner, T.C. Memo. 2020-116; Smith Lake, LLC v. Commissioner, T.C. \nMemo. 2020-107; Lumpkin One Five Six, LLC v. Commissioner, T.C. Memo. \n2020-94. \n(7) Examiners should contact Counsel for assistance in review of deeds and lender \nagreements to determine if the documents satisfy the allocation of proceeds \nrequirements of Treas. Reg. § 1.170A-14(g)(6)(ii). \nIV. Qualified Organization \nA. Overview \n(1) A taxpayer must transfer the conservation easement to an eligible donee to \nqualify for a contribution deduction. An eligible donee: \n• Is a qualified organization, \n• Must have the commitment to protect the conservation purpose(s) of the \ndonation, and \n• Must have the resources to enforce the conservation restrictions. \n(2) See IRC § 170(h)(3); Treas. Reg. § 1.170A-14(c)(1). \nB. Qualified Organization \n(1) A qualified organization is one of the following: \n• A governmental unit, including the U.S. government, a U.S. possession, \nthe District of Columbia, a state government, or any political subdivision of \na state or U.S. possession so long as the contribution is made for \nexclusively public purposes. \n• A public charity described in IRC § 501(c)(3) that meets the public support \ntest of IRC § 509(a)(2) or a public charity described in 170(b)(1)(A)(vi). \n• A public charity described in IRC § 501(c)(3) that meets the requirements \nof IRC § 509(a)(3) and is controlled by one of the organizations described \nabove. Treas. Reg. § 1.170A-14(c)(1). \nC. Commitment and Resources \n(1) The qualified organization must have the commitment to protect the \nconservation purpose(s) of the donation Treas. Reg. § 1.170A- 14(c)(1). An \nentity organized or operated for one of the conservation purposes in IRC § \n170(h)(4)(A) is considered to have the commitment required to protect the \nconservation purposes of the donation. Treas. Reg. § 1.170A-14(c)(1). \n(2) Qualified organizations that accept easement contributions and are committed \nto conservation will generally have an established monitoring program, such as \nannual property inspections to ensure compliance with the conservation \neasement terms and to protect the easement in perpetuity. The terms of the \n", "29 \n \neasement contribution must permit the qualified organization access to the \nproperty for inspection. Treas. Reg. § 1.170A-14(g)(5)(ii). \n(3) The qualified organization must also have the resources to enforce the \nrestrictions of the conservation easement. Resources do not necessarily mean \ncash. Treas. Reg. § 1.170A-14(c)(1). Resources may be in the form of the \nvolunteer services of lawyers who provide legal services or conservationists \nwho inspect the property and prepare monitoring reports. \n(4) See Chapter 12 for suggestions on how to evaluate the organization’s \ncommitment and resources. \nD. Special Rules for Buildings in a Registered Historic District \n(1) For a contribution made after July 25, 2006, of a qualified real property interest \nwith respect to a building in a registered historic district, an additional \nrequirement must be met to satisfy the commitment and resources test. Section \n170(h)(4)(B)(ii) requires the taxpayer and the donee organization to execute a \nwritten agreement certifying, under penalty of perjury, that the donee is a \nqualified organization with a purpose of environmental protection, land \nconservation, open space preservation, or historic preservation, and that the \ndonee has the resources to manage and enforce the restriction and a \ncommitment to do so. The taxpayer is also required to attach to its return a \ncopy of the qualified appraisal for the qualified property interest, photos of the \nentire exterior of the building and a description of all restrictions on the \ndevelopment of the building. IRC § 170(h)(4)(B)(iii)(I-III). \n(2) Note: This special rule does not apply to properties listed on the National \nRegister. \n(3) See Chapter 5 for a complete discussion of the special rules for buildings in \nregistered historic districts. \nE. Cash Contributions \n(1) A common practice for qualified organizations is to request a cash contribution \n(sometimes referred to as a “stewardship fee”) from donors of conservation \neasements. To be deductible as a charitable contribution, the cash payment \nmust be a voluntary transfer made with charitable intent to a qualified \norganization. IRC § 170 (a) and (c). All cash contributions, regardless of \namount, must be substantiated with a bank record or a receipt from the donee. \nThe record or receipt must show the name of the donee, the date of the \ncontribution, and the amount of the contribution. IRC § 170(f)(17); Treas. Reg. \n§ 1.170A-15. \n(2) Charitable intent exists if the transfer is made without the receipt of, or the \nexpectation of receiving, a quid pro quo for the transfer. Generally, if the \nbenefits the transferor receives or expects to receive are substantial, rather \nthan incidental to the transfer, the transfer does not satisfy the charitable intent \n", "30 \n \nrequirement under IRC § 170. Hernandez v. Commissioner, 490 U.S. 680, 691 \n(1989); United States v. American Bar Endowment, 477 U.S. 105, 117-118 \n(1986); Wendell Falls Development, LLC v. Commissioner, T.C. Memo. 2018-\n45, at 10-13; Singer Co. v. United States, 196 Ct. Cl. 90, 106 449 F.2d 413, \n422-423 (1971). \n(3) If a direct or indirect economic benefit (other than a tax deduction) is received or \nis expected to be received as a result of making a contribution, the deduction \nmay be limited or disallowed. See generally § 1.170A-1(h)(3), which was \npublished on June 13, 2019. A state or local tax credit is a direct or indirect \neconomic benefit that reduced the amount of a taxpayer’s charitable \ncontribution deduction. \nE.1. Quid Pro Quo Contribution \n(1) A quid pro quo contribution is a transfer of money or property made to a \nqualified organization partly in exchange for goods or services in return from the \ncharity or a third party. A quid pro quo may also be in the form of an indirect \nbenefit from a third party. \n• Example: A land developer agrees to grant a conservation easement to \nthe county or other qualified organization in exchange for the approval of a \nproposed subdivision. See Triumph Mixed Use Investments III, LLC v. \nCommissioner, T.C. Memo. 2018-65. 31-42. \n(2) If a taxpayer receives a quid pro quo, the transfer to the charity may be \ndeductible as a charitable contribution, but only to the extent the amount \ntransferred exceeds the FMV of the quid pro quo, and only if the excess amount \nwas transferred with charitable intent. United States v. American Bar \nEndowment, 477 U.S. 105, 117 (1986). \n(3) The burden is on the taxpayer to show that all or part of a payment is a \ncharitable contribution or gift. Treas. Reg. § 1.170A-1(h)(1) and (2); United \nStates v. American Bar Endowment, 477 U.S. 105, 116-118 (1986); and Rev. \nRul. 67-246, 1967-2 C.B. 104. \nV. Conservation Purpose \nA. Overview \n(1) A contribution of a conservation easement to a qualified organization must be \nmade for one of the following conservation purposes: \n• Preservation of land areas for outdoor recreation by, or the education of, \nthe general public. \n• Protection of a relatively natural habitat for fish, wildlife, or plants, or a \nsimilar ecosystem. \n• Preservation of open space for the scenic enjoyment of the general public, \nor pursuant to a federal, state, or local governmental conservation policy, \nboth yielding a significant public benefit. \n", "31 \n \n• Preservation of historically important land area or certified historic building. \n(2) IRC § 170(h)(4)(A). \n(3) The conservation easement must be transferred by deed (or other legal \ninstrument as appropriate under the law of the relevant State) and recorded \nwhere the property is located, be exclusively for conservation purposes, \nprotected in perpetuity, and meet at least one of the above conservation \npurposes. \n(4) Any required access to the land by the general public depends on the \nconservation purpose of the conservation easement. If the claimed \nconservation purpose is for the preservation of open space under IRC § \n170(h)(4)(A)(iii), the contribution must yield a significant public benefit which is \nusually by visual access from a public highway. Treas. Reg. § 1.170A-\n14(d)(4)(ii)(B). \n(5) The deed of conservation easement must prohibit inconsistent use of the \nproperty that could permit destruction of a significant conservation interest, \neven if the easement accomplishes an enumerated conservation purpose. \nTreas. Reg. § 1.170A-14(e)(2). \n(6) A baseline study is used to identify the conservation attributes and to establish \nthe condition of the property at the time of the conservation easement donation. \nTreas. Reg. § 1.170A-14(g)(5). \nB. Land for Outdoor Recreation or Education \n(1) This category includes the donation of a qualified real property interest to \npreserve land for outdoor recreation by, or for the education of, the general \npublic. IRC § 170(h)(4)(A)(i). \n(2) Substantial and regular physical access by the general public to the preserved \nland is required. Treas. Reg. § 1.170A-14(d)(2)(ii). \n• Examples: A donation to preserve a lake for use by the general public for \nboating or fishing, or to preserve land for a hiking trail. \n(3) See Treas. Reg. § 1.170A-14(d)(2) for additional guidance. \n(4) See also PPBM-Rose Hill, Limited v. Commissioner, 900 F.3d 193 (5th Cir. \n2018). In denying the charitable contribution deduction because the taxpayer \nfailed to comply with the extinguishment clause requirements in Treas. Reg. § \n1.170A-14(g)(6)(ii), the Fifth Circuit Court of Appeals reversed the tax court on \nthe issue of whether the conservation easement met the outdoor recreation \nconservation purpose. The court determined that the easement met the outdoor \nrecreation conservation purpose because the terms of the deed stated that the \nproperty was being protected for outdoor recreation “for use by the general \npublic.” \nC. Relatively Natural Habitat or Ecosystem \n", "32 \n \n(1) This conservation purpose is satisfied if the conservation easement protects a \nsignificant relatively natural habitat of fish, wildlife or plants, or similar \necosystem. IRC § 170(h)(4)(A)(ii). An ordinary tract of land where a common \nfish, wildlife or plant community, or similar ecosystem normally lives does not \nsatisfy this conservation purpose. Treas. Reg. § 1.170A- 14(d)(3)(ii). \n(2) Significant habitats and ecosystems include, but are not limited to: \n• Habitats for rare, endangered, or threatened species. \n• Natural areas that are relatively intact and are considered high quality \nexamples of land or aquatic communities. \n• Natural areas that are in or contribute to the ecological viability of a park, \npreserve, wildlife refuge, wilderness area, or other similar conservation \narea. \n(3) For this conservation purpose, limitations on public access are allowable. For \nexample, a restriction on all public access to the habitat of a threatened native \nanimal species would not defeat the claimed deduction. Treas. Reg. § 1.170A-\n14(d)(3)(iii). The taxpayer’s documentation, called a baseline report, as required \nby Treas. Reg. § 1.170A-14(g)(5)(i), should clearly describe and identify the \nrelative natural habitat or ecosystem being protected on the property. \n(4) The determination of what specifically meets this conservation purpose test is \nbased on the facts and circumstances of the specific case. In Glass v. \nCommissioner, 124 T.C. 258 (2005), aff’d, 471 F.3d 698 (6th Cir. 2006), the \ntaxpayer donated two easements that restricted the development of a fraction of \na 10-acre parcel of residential property. The tax court held that the conservation \npurpose of natural habitat was satisfied because the conservation easements \nwere placed on property that had possible places to create or promote a \nrelatively natural habitat of plants or wildlife. \n(5) In Atkinson v. Commissioner, T.C. Memo. 2015-236, taxpayer claimed \ndeductions for conservation easements encumbering non-contiguous tracts of \nland on and adjacent to golf courses located in a gated and guarded residential \ncommunity. The tax court distinguished the Glass case and held that the \neasements did not protect a relatively natural habitat. In so holding, the tax \ncourt reasoned, among other things, that the golf courses’ use of pesticides \ncould destroy the ecosystem of the encumbered property. The tax court’s \nreliance on the Service’s expert reports and testimony in Atkinson demonstrates \nthe importance of expert evidence in “protecting natural habitat” cases. \n(6) In Champions Retreat Golf Founders, LLC. v. Commissioner, T.C. Memo. 2018-\n146, taxpayer claimed a deduction for an easement on approximately 350 acres \nthat encumbered most of a golf course scattered among houses in a gated \nresidential community. Taxpayer argued the easement satisfied conservation \npurposes by preserving habitat for \"species of conservation concern,\" and \nproviding open space for scenic enjoyment of the general public and pursuant \nto a clearly delineated governmental policy. The court sustained the \n", "33 \n \ndisallowance, finding that that the easement failed to satisfy either the habitat \npurpose or the open space purpose. The court held there was an insufficient \npresence of rare, endangered, or threatened species, and the encumbered land \nwas in a non-natural state. Finally, the court held that open space conservation \npurpose was not met because there was insufficient physical and visual access \nfor the public to enjoy the encumbered land in the gated community. Moreover, \nthe court held that the easement did not satisfy a clearly delineated \ngovernmental policy since the state statute cited by the taxpayer did not support \na determination that the encumbered property was a part of an “identified \nconservation project.” As in the Atkinson case, the tax court relied on expert \nreports and testimony to determine that the taxpayer failed to satisfy the \nconservation purposes of IRC § 170(h). On appeal, the Eleventh Circuit Court \nof Appeals disagreed with the tax court and vacated and remanded the tax \ncourt opinion. Champion’s Retreat Golf Founders, LLC v. Commissioner, 959 \nF.3d 1033 (11th Cir. 2020). A Motion to Amend the Opinion, filed in the 11th \nCircuit Court of Appeals on behalf of the Commissioner, is currently pending. \nD. Open Space \n(1) The donation of a qualified real property interest to protect open space \n(including farmland and forest land) must be (1) for the scenic enjoyment of the \ngeneral public, or (2) pursuant to a clearly delineated federal, state, or local \ngovernmental conservation policy. This type of conservation easement must \npreserve open space and must yield a significant public benefit. IRC § \n170(h)(4)(A)(iii). \nD.1. Scenic Enjoyment \n(1) Preservation of open space may be for the scenic enjoyment of the general \npublic if development of the property would impair the scenic character of the \nlocal rural or urban landscape or interfere with a scenic panorama that can be \nenjoyed by the public. Treas. Reg. § 1.170A- 14(d)(4)(ii)(A). \n(2) Whether the easement provides scenic enjoyment to the general public is \nevaluated based on all the facts and circumstances. The burden of proof is on \nthe taxpayer to show the scenic characteristics of the property. \n(3) Treas. Reg. § 1.170A-14(d)(4)(ii)(A) lists factors to consider: \n• The compatibility of the land use with other land in the vicinity. \n• The degree of contrast and variety provided by the visual scene. \n• The openness of the land (which would be a more significant factor in an \nurban or densely populated setting or in a heavily wooded area). \n• Relief from urban closeness. \n• The harmonious variety of shapes and textures. \n", "34 \n \n• The degree to which the land use maintains the scale and character of the \nurban landscape to preserve open space, visual enjoyment and sunlight \nfor the surrounding area. \n• The consistency of the proposed scenic view with a methodical state \nscenic identification program, such as a state landscape inventory. \n• The consistency of the proposed scenic view with a regional or local \nlandscape inventory made pursuant to a sufficiently rigorous review \nprocess, especially if the donation is endorsed by an appropriate state or \nlocal governmental agency. \n(4) A conservation easement preserving open space for the scenic enjoyment of \nthe general public does not require physical access by the public. Visual access \nto or across the property by the general public is sufficient. Although the entire \nproperty need not be visible to the public in order to qualify for a deduction, the \npublic benefit from the donation may be insufficient to qualify if only a small \nportion of the property is visible to the public. Treas. Reg. § 1.170A-\n14(d)(4)(ii)(B). \n(5) In Turner v. Commissioner, 126 T.C. 299 (2006), the conservation purpose of \nopen space was not met because the easement deed did not protect the views \nof the property. The taxpayer was not entitled to a deduction because the \nconservation easement did not satisfy one of the required conservation \npurposes in IRC § 170(h)(4)(A). \n(6) See Treas. Reg. § 1.170A-14(d)(4)(ii) for additional guidance. \nD.2. Governmental Conservation Policy \n(1) Conservation purpose includes the preservation of open space where such \npreservation is pursuant to a clearly delineated federal, state, or local \ngovernment conservation policy. IRC § 170(h)(4)(A)(iii)(II). \n(2) A broad declaration by a single official or legislative body that the land should \nbe conserved is not sufficient. The donation must further a specific, identified \nconservation project. The fact that the donation was accepted by a government \nagency is not sufficient to satisfy this requirement. The more rigorous the review \nprocess by the governmental agency, the more the acceptance of the easement \ntends to establish the requisite clearly delineated governmental policy. Treas. \nReg. § 1.170A-14(d)(4)(iii)(B). \n(3) The government need not fund the conservation program, but it must involve a \nsignificant commitment by the government with respect to the conservation \nproject. \n(4) Public access is not required if the conservation purpose would be undermined \nor frustrated by the public access. Treas. Reg. § 1.170A-14(d)(4)(iii)(C). \nD.3. Significant Public Benefit \n", "35 \n \n(1) A conservation purpose based on the preservation of open space, whether for \nscenic enjoyment or pursuant to a governmental conservation policy, must yield \na significant public benefit. IRC § 170(h)(4)(A)(iii). \n(2) A determination of whether a conservation easement provides a significant \npublic benefit must be based on all facts and circumstances. Treas. Reg. § \n1.170A-14(d)(4)(iv) lists a number of factors that may be considered: \n• Uniqueness of the property to the area. \n• Intensity of land development in the area. \n• Consistency of the proposed open space use with public programs for \nconservation in the region. \n• Consistency of proposed open space use with existing private \nconservation programs in the area, evidenced by other protected land held \nby a qualified organization in close proximity to the property. \n• Likelihood the property would be developed in the absence of the \neasement. \n• Opportunity of the public to appreciate the property's scenic values. \n• Importance of the property to preserve a landscape or resource that \nattracts tourism or commerce. \n• Likelihood of the donee acquiring substitute property or property rights. \n• Cost of enforcing the terms of the conservation restrictions. \n• Population density in the area. \n• Consistency of open space use with a legislatively mandated program \nidentifying particular parcels of land for future protection. \n(3) The preservation of an ordinary tract of land would not, in and of itself, yield a \nsignificant public benefit. Treas. Reg. § 1.170A-14(d)(4)(iv)(B). A charitable \ncontribution will not be allowed if an easement does not impose new or \nexpanded restrictions on the property. A conservation easement that merely \nlimits the number of lots that the acreage is divided into does not necessarily \nsatisfy the open space requirement of IRC § 170(h). Turner v. Commissioner, \n126 T.C. 299 (2006). \n(4) The legislative history underlying IRC § 170(h) shows that Congress did not \nintend for every easement to qualify for a deduction. A deduction is not allowed \nunless there is an assurance that the public benefit furthered by the contribution \nwould be substantial enough to justify the allowance of a deduction. S. Rep. 96-\n1007, at 9-10 (1980), reprinted in 1980 U.S.C.C.A.N. 6736, 6744-45. \n• Example: Significant public benefit includes the preservation of a unique \nnatural land formation for the enjoyment of the general public or the \npreservation of woodland along a well-traveled public highway to preserve \n", "36 \n \nthe appearance of the area so as to maintain the scenic view from the \nhighway. \nE. Historically Important Land or Structure \n(1) This category includes the donation of a qualified real property interest to \npreserve a historically important land area or a certified historic structure. IRC § \n170(h)(4)(A)(iv). \nE.1. Historically Important Land \n(1) Historically important land includes: \n• An independently significant land area that meets the National Register \nCriteria for Evaluation. \n• Land within a registered historic district and buildings on the land area that \nis reasonably considered as contributing to the significance of the district. \n• Land where the physical or environmental features contribute to the \nhistoric or cultural importance and continuing integrity of certified historic \nstructures. \n(2) See Treas. Reg. § 1.170A-14(d)(5)(ii) for additional guidance. \n(3) Under the Pension Protection Act (IRC § 170(h)(4)(C)), a “certified historic \nstructure” includes a land area listed in the National Register of Historic Places. \nThe National Register is part of a national program administered by the National \nPark Service (NPS) to identify, evaluate and protect historic and archeological \nresources worthy of preservation. A list of properties in the National Register \ncan be found on the NPS Web page. \nE.2. Certified Historic Structure \n(1) A certified historic structure is: \n• Any building, structure, or land area listed on the National Register, or \n• Any building located in a registered historic district and certified by the \nSecretary of the Interior as being of historic significance to the district. \n(2) A certified historic structure may be a commercial property or a personal \nresidence. \n(3) The NPS Technical Preservation Services administers the certification program \nfor the Department of the Interior. This certification application is submitted \nthrough the taxpayer’s State Historic Preservation Office, which makes a \nrecommendation to the NPS regarding the application. The certification must be \ndone at the time the easement is donated or by the due date (including \nextensions) of the return for the year of the donation. Treas. Reg. § 1.170A-\n14(d)(5)(iii). \n", "37 \n \n(4) The term “registered historic district” includes a district described in IRC § \n47(c)(3)(B) and includes: \n• Any district listed in the National Register, and \n• Any district: \n• designated under a statute of the appropriate state or local \ngovernment, if such statute is certified by the Secretary of the \nInterior as containing criteria which will substantially achieve the \npurpose of preserving and rehabilitating buildings of historic \nsignificance to the district, and \n• that is certified by the Secretary of the Interior as meeting \nsubstantially all of the requirements for the listing of districts in the \nNational Register. \n(5) A building in a local historic district will not meet the definition of a certified \nhistoric structure unless both the structure and the district have been certified in \naccordance with IRC § 47. \nE.3. Special Rules for Buildings in Registered Historic Districts \n(1) Section 170(h)(4)(B) imposes additional requirements for contributions of \nconservation easements on the exterior of a building in a registered historic \ndistrict. Note: These requirements do not apply to properties listed in the \nNational Register. \n(2) To qualify, all of the following additional requirements must be met: \n• The entire exterior of the building, including the front, sides, rear, and \nheight, must be restricted, and no changes can be made to the exterior \nthat are inconsistent with the historical character of the exterior. \n• The donor must enter into a written agreement with the donee certifying, \nunder penalty of perjury, that the donee is a qualified organization with a \npurpose of environmental protection, land conservation, open space \npreservation, or historic preservation, and that the donee has the \nresources to manage and enforce the restrictions and the commitment to \ndo so. \n• Donors must attach to the return a qualified appraisal as defined in IRC § \n170(f)(11)(E), photographs of the entire exterior of the building, and a \ndescription of all restrictions on the development of the building. \n• Donors must pay a $500 filing fee to the U.S. Treasury if a deduction of \nmore than $10,000 is claimed. IRC § 170(f)(13). \n(3) Some visual access by the public to the building, structure or land area is \nrequired. The terms of the easement must be such that the general public is \ngiven the opportunity on a regular basis to view the characteristics and features \n", "38 \n \nof the property. Factors to be considered in determining the type of access for \nhistoric properties include: \n• Historical significance of the property; \n• The nature and features that are the subject of the easement; \n• The remoteness or accessibility of the site of the donated property; \n• The possibility of physical hazards to the public visiting the property; \n• The extent to which public access would be an unreasonable intrusion on \nany privacy interests of individuals living on the property; \n• The degree to which public access would impair the preservation interests \nwhich are the subject of the donation; and \n• The availability and opportunities for the public to view the property by \nmeans other than visits to the site. \n(4) See Treas. Reg. § 1.170A-14(d)(5)(iv) for additional guidance. \nF. Public Access \n(1) Public access (either physical or visual) to the property is generally required for \nthe conservation easement to be deductible except with respect to protection of \na relatively natural habitat or ecosystem or pursuant to specified governmental \npolicies. The type of access depends on the claimed conservation purpose. \n(2) If physical access is required, access must be substantial and on a regular \nbasis. \n(3) If only visual access is required, the entire property need not be visible to the \npublic for a donation to qualify. However, the public benefit from the donation is \ninsufficient to qualify for a deduction if only a small portion of the property is \nvisible to the public. \n(4) See Treas. Reg. § 1.170A-14(d) for specific access requirements. \nG. Inconsistent Uses \n(1) A donation must be exclusively for conservation purposes, and generally the \ndeed of conservation easement must prohibit inconsistent uses. An inconsistent \nuse allows for the destruction or potential destruction of significant conservation \ninterests in conflict with a conservation purpose. \n(2) However, some inconsistent uses are permitted if necessary to protect the \nconservation interests that are the subject of the easement. \n(3) All conservation easements reserve some rights for the owner of the \nencumbered property. Depending on the nature and extent of these reserved \nrights, the claimed conservation purpose may be impaired to such a degree that \nthe contribution may not be allowable. A determination of whether the reserved \n", "39 \n \nrights defeat the conservation purpose must be determined based on all facts \nand circumstances. \n• Example: The conservation purpose of the easement as described in the \nconservation easement deed was to protect the relatively natural habitat \nfor scrub jay, a threatened bird. The deed of easement allows the taxpayer \nto use pesticides that would destroy the natural food source for the scrub \njay. The taxpayer is not entitled to a deduction because the allowed \nactivity is an inconsistent use. \n(4) See Treas. Reg. § 1.170A -14(e)(2) and (e)(3) for additional guidance. \nH. Baseline Study \n(1) When a donor reserves a Taxright, the exercise of which may impair \nconservation interests associated with the encumbered property, the donor \nmust provide the donee organization with documentation sufficient to establish \nthe condition of the property at the time of the donation. The donor must provide \nbaseline documentation to the donee prior to the time the donation is made. \nTreas. Reg. § 1.170A-14(g)(5)(i). This documentation should provide specific \ninformation about the conservation values of the property. \n(2) The baseline documentation is generally prepared by a person with specific \ntraining in the assessment of conservation values such as a biologist, botanist, \nor historian. The baseline study may be prepared by a person affiliated with the \ndonee organization. \n(3) This documentation may include: \n• Survey maps from the U.S. Geological Survey, showing the property line \nand other contiguous or nearby protected areas. \n• A map of the area drawn to scale showing all existing man-made \nimprovements or incursions (such as roads, buildings, fences, or gravel \npits) and vegetation, and identification of flora and fauna (including, for \nexample, rare species locations, animal breeding and roosting areas, and \nmigration routes), land use history (including present uses and recent past \ndisturbances), and distinct natural features (such as large trees and \naquatic areas). \n• An aerial photograph of the property. \n• On-site photographs taken at appropriate locations on the property. \n(4) The documentation must be accompanied by a statement signed by the donor \nand a representative of the donee organization affirming that the documentation \nis an accurate representation of the protected property at the time of the \ntransfer. \n(5) See Treas. Reg. § 1.170A-14(g)(5)(i) for additional guidance. \nVI. Substantiation \n", "40 \n \nA. Overview \n(1) A charitable contribution is not deductible unless properly substantiated in \naccordance with the Internal Revenue Code and applicable regulations, \nincluding: \n• IRC § 170(a)(1) \n• IRC § 170(f)(8) \n• IRC § 170(f)(11) \n• IRC § 170(f)(13) \n• Treas. Reg. § 1.170A-13 \n• Treas. Reg. § 1.170A-14 \n• Treas. Reg. § 1.170A-16 \n• Treas. Reg. § 1.170A-17 \n(2) These IRC sections and corresponding regulations describe the specific \nsubstantiation and recordkeeping requirements for donors of noncash \ncontributions. Note that substantiation requirements for noncash contributions \nmade on or before July 30, 2018, are generally governed by Treas. Reg. § \n1.170A-13, while substantiation requirements for noncash contributions made \nafter July 30, 2018, are generally governed by Treas. Reg. § 1.170A-16. Treas. \nReg. § 1.170A-16(g). Where appropriate, both regulations are cited below. \nTreas. Reg. § 1.170A-17 is applicable to contributions made on or after January \n1, 2019. \n(3) The kind of documents required to substantiate a charitable contribution vary \ndepending on the amount, date of contribution, and type of property contributed. \n(4) The burden is on the taxpayer to demonstrate that the property transferred to \nthe qualified organization is a deductible contribution. See Treas. Reg. § \n1.170A-1(h)(1) and (2); United States v. American Bar Endowment, 477 U.S. \n105, 116-118 (1986); and Revenue Ruling 67-246, 1967-2 C.B. 104. \n(5) See Publication 1771, Charitable Contributions-Substantiation and Disclosure \nRequirements (PDF), Publication 526, Noncash Contributions (PDF), and \nPublication 561, Determining the Value of Donated Property (PDF), for \nadditional information. \n(6) See Exhibit 6-1 for a summary of substantiation requirements. \nB. Contemporaneous Written Acknowledgment \n(1) A contemporaneous written acknowledgment (CWA) by the qualified donee \norganization is required for all contribution deductions of $250 or more, whether \nin cash or property. \n", "41 \n \n(2) “Contemporaneous” means that the taxpayer must obtain the acknowledgment \nby the earlier of the date on which the taxpayer files his or her tax return \nclaiming the charitable contribution deduction, or the due date (including \nextensions) for the return. IRC § 170(f)(8); Treas. Reg. § 1.170A-13(f)(3); and \nPublication 1771, Charitable Contributions-Substantiation and Disclosure \nRequirements (PDF). \n(3) This acknowledgment by the qualified donee organization must contain: \n• Amount of any cash contribution, \n• Description (but not the value) of the property contributed, \n• Statement that no goods or services were provided by the organization in \nreturn for the contribution (if this was the case), \n• Description and good faith estimate of the value of goods or services, if \nany, that an organization provided in return for the contribution, and \n• A statement that goods or services (if any) that an organization provided in \nreturn for the contribution consisted entirely of intangible religious benefits \n(if this was the case). \n(4) See Treas. Reg. § 1.170A-13(f)(2). \n(5) Section 170(f)(8) requirements must be complied with for a deduction to be \nallowed. See Addis v. Commissioner, 374 F.3d 881, 887 (9th Cir. 2004), aff’g, \n118 T.C. 528 (2002) (“the deterrence value of section 170(f)(8)’s total denial of \na deduction comports with the effective administration of a self-assessment and \nself-reporting system”), cited in Viralam v. Commissioner, 136 T.C. 151; \nSchrimsher v. Commissioner, T.C. Memo. 2011-71. \n(6) The following CWA does not meet the statutory requirement of IRC § 170(f)(8) \nbecause it does not make an affirmative statement that no goods or services \nwere provided (or describe if goods or services were actually provided) in \nexchange for the contribution. \n• Example: “Thank you for your contribution by deed of a conservation \neasement on XYZ property and $10,000 cash contribution for \nmaintenance of the easement that ABC Land Trust received on May 5, \n2018.” \n(7) A CWA is not required to take any particular form, and an easement deed may \nqualify as a CWA under certain circumstances. Unless the deed expressly \nstates the total value of the goods or services received by the donor in \nexchange for the contribution, the deed taken as a whole must provide that no \ngoods or services were received in exchange. Schrimsher v. Commissioner, \nT.C. Memo. 2011-71. The tax court has held that a deed qualified as a CWA \nwhen no valuable consideration was mentioned in the deed and the deed \ncontained a merger clause. Averyt v. Commissioner, T.C. Memo. 2012-198; RP \nGolf, LLC v. Commissioner, T.C. Memo. 2012-282. A merger clause provides \n", "42 \n \nthat the particular deed sets forth the entire agreement of the parties regarding \nthe contribution of the conservation easement and supersedes all prior \ndiscussions, negotiations, or agreements relating to the easement. French v. \nCommissioner, T.C. Memo. 2016- 53, held that in the case of a deed without an \nindication that there were no goods or services provided, unless there is a \nmerger clause, the deed cannot be taken as a whole to qualify as a CWA. In \nsuch a case, the absence of a merger clause means that a donor could have \nreceived consideration in exchange for the contribution even if the deed does \nnot mention that there was any valuable consideration transferred. \n(8) Some deeds recite the amount of consideration as \"$1.00 and other good and \nvaluable consideration.\" Numerous state courts have held that phrase is \ninherently and intrinsically ambiguous. The phrase may mean that no real \nconsideration was given, that the consideration was nominal, or that the \nconsideration was substantial but was not disclosed. Nevertheless, in the \nabsence of any other evidence concerning the amount of consideration, the tax \ncourt has held that a deed can satisfy the CWA requirements even if it \ndescribes the consideration as “$1.00 and other good and valuable \nconsideration” as long as the deed contains a merger clause. 310 Retail, LLC v. \nCommissioner, T.C. Memo. 2017-164, and Big River Dev., L.P. v. \nCommissioner, T.C. Memo. 2017-166. \n(9) If you have any questions about whether the deed language satisfies the \nrequirements for a CWA under IRC § 170(f)(8), consult with Counsel. \n(10) \nIn IRC § 170(f)(8)(D), Congress provided an exception to the CWA requirement. \nSection 170(f)(8)(D) states that a CWA is not required if the donee organization \nfiles a return on such form and in accordance with such regulations as the \nTreasury Department may prescribe (donee reporting). In the Tax Cuts and \nJobs Act, Congress deleted subparagraph (D) and redesignated what had been \nsubparagraph (E) as subparagraph (D), effective for contributions made in tax \nyears beginning after December 31, 2016. Even before that effective date, the \nIRC § 170(f)(8)(D) exception was not effective. 15 West 17th St. v. \nCommissioner, 147 T.C. No. 19 (2016). \n(11) \nNote: Taxpayers and return preparers frequently confuse the CWA requirement \nwith the filing of Form 8283, Noncash Charitable Contributions (PDF). This form \nis not a substitute for the CWA; both are required. Failure to meet either \nrequirement may result in disallowance of the charitable contribution deduction. \nC. Form 8283, Noncash Charitable Contributions \nC.1. Generally \n(1) Section B of Form 8283, Noncash Charitable Contributions (PDF), referred to in \nthe Deficit Reduction Act of 1984 and in Treas. Reg. § 1.170A-13(c)(4) as an \n“appraisal summary,” must be fully completed and attached to the return for \nnoncash donations greater than $5,000. \n", "43 \n \n(2) Note: If the donation originates from a flow-through entity (such as S \ncorporation or partnership), the partner or shareholder who receives an \nallocation of the charitable contribution must attach a copy of the flow-through \nentity’s appraisal summary (Form 8283) to the tax return on which the \ndeduction for the contribution is first claimed. Treas. Reg. § 1.170A- \n13(c)(4)(iv)(G); Treas. Reg. § 1.170A-16(f)(4)(ii). \n(3) Form 8283, Section B is often improperly completed. Common errors include: \n• Inadequate description of the property \n• Missing information \n• Missing signatures \n• Inconsistent dates \n(4) The description of the property must have sufficient detail for a person \nunfamiliar with the type of property to ascertain that the property being \nappraised is the property that was contributed. Treas. Reg. § 1.170A-\n13(c)(4)(ii)(B). A similar rule applies under Treas. Reg. § 1.170A-16(d)(3)(iv)(B). \n(5) Form 8283, Section B, Part I, requests information regarding: \n• Acquisition date of the property \n• How the property was acquired by the donor \n• Donor’s cost or adjusted basis \n• Bargain sale amount received \n• Appraised FMV of the easement \n(6) For conservation easements, the instructions to Form 8283 also require a \nstatement that identifies the conservation purpose, shows FMV before and \nafter, states whether the donation was made in order to get an approval or was \nrequired by contract, and whether the taxpayer or related person has any \ninterest in nearby property. This statement, described in the Instructions to the \nForm 8283, must be attached to the Form 8283. \n(7) See Instructions for Form 8283, Noncash Charitable Contributions (PDF), and \nTreas. Reg. § 1.170A-13(c)(4); Treas. Reg. § 1.170A-16(d)(3) for detailed \ndiscussion of the appraisal summary (Form 8283) requirements. \n(8) In Belair Woods, LLC v. Commissioner, T.C. Memo. 2018-159, the tax court \nheld that the taxpayer’s Form 8283 appraisal summary did not comply with \nTreas. Reg. § 1.170A-13(c)(4) when the taxpayer failed to include its cost basis \nin the property on Form 8283 and the taxpayer’s explanation in the statement \nattached to Form 8283 did not show that it was unable to provide such \ninformation. The deduction was therefore disallowed. \nC.2. Declaration of Appraiser \n", "44 \n \n(1) Form 8283, Section B, Part III, Declaration of Appraiser, must be completed by \nthe qualified appraiser for donations in excess of $5,000. Treas. Reg. § 1.170A-\n13(c)(4)(ii)(K) and (L); Treas. Reg. § 1.170A-16(d)(3)(iii) and (d)(4). \nC.3. Donee Acknowledgment \n(1) Form 8283, Section B, Part IV, Donee Acknowledgment, must be signed by an \nofficial authorized to sign the tax or information returns of the donee \norganization or a person specifically authorized by such official to sign Form \n8283. Treas. Reg. § 1.170A-13(c)(4)(iii); Treas. Reg. § 1.170A-16(d)(5)(i). \nC.4. Failure to Attach Form 8283 \n(1) For contributions made on or before July 30, 2018, the failure to file Form 8283 \nresults in disallowance of the charitable contribution deduction for the \nconservation easement unless: \n• Such failure was due to a “good-faith omission,” \n• The donor otherwise complied with Treas. Reg. § 1.170A-13(c)(3) and \n(c)(4) (including completion of a timely qualified appraisal), and \n• The IRS requests that the donor submit a fully completed form within 90 \ndays of the request, and the donor complies. Treas. Reg. § 1.170A-\n13(c)(4)(iv)(H). \n(2) In rare and unusual circumstances in which it is impossible for the taxpayer to \nobtain the signature of the donee, the taxpayer’s deduction will not be \ndisallowed for that reason provided that the taxpayer attaches a statement to \nthe Form 8283 explaining, in detail, why it was not possible to obtain the \ndonee’s signature. Treas. Reg. § 1.170A-13(c)(4)(iv)(C)(2). \nD. Qualified Appraisal \n(1) Qualified appraisals are required for all contribution deductions for conservation \neasements valued at more than $5,000. IRC § 170(f)(11)(C). \n(2) To be a qualified appraisal under IRC § 170(f)(11)(E), an appraisal of property \n(1) must be treated as a qualified appraisal under regulations or other guidance \nprescribed by the Secretary and (2) must be conducted by a qualified appraiser \nin accordance with generally accepted appraisal standards and any regulations \nor other guidance prescribed by the Secretary. See also Notice 2006-96, 2006-\n2 C.B. 902, for rules applicable to contributions made before January 1, 2019, \nthe effective date of Treas. Reg. § 1.170A-17. \nD.1. Qualified Appraisal Under Regulations \n(1) Treas. Reg. § 1.170A-13(c)(3) and Treas. Reg. § 1.170A-17(a)(3) define a \nqualified appraisal as a document that, among other things: (1) relates to an \nappraisal that is made not earlier than 60 days before the date of contribution of \nthe appraised property and no later than the due date (including extensions) of \n", "45 \n \nthe return on which a deduction is first claimed under IRC § 170; (2) is \nprepared, signed, and dated by a qualified appraiser; (3) includes, among other \nrequirements, (a) a description of the property appraised; (b) the FMV of such \nproperty and the specific basis for the valuation, (c) a statement that such \nappraisal was prepared for income tax purposes; (d) the qualifications of the \nqualified appraiser; and (e) the signature and taxpayer identification number of \nsuch appraiser; and (4) does not involve an appraisal fee that violates certain \nprescribed rules. \nD.2. Generally Accepted Appraisal Standards \n(1) Section 170(f)(11)(E) specifies that the qualified appraisal must be conducted \nby a qualified appraiser in accordance with generally accepted appraisal \nstandards. \n(2) If a charitable contribution deduction of more than $500,000 is claimed for a \nnoncash contribution, the taxpayer must attach a copy of a qualified appraisal of \nthe property to the return for the year of donation. IRC § 170(f)(11)(D). \n(3) Special rule: For contributions of façade easements in registered historic \ndistricts, a qualified appraisal must be attached to the return regardless of the \ndollar amount claimed for the conservation easement. IRC § 170(h)(4)(B)(iii)(I). \nNote: This special rule does not apply to properties listed on the National \nRegister. \nD.3. Reasonable Cause \n(1) If the taxpayer fails to obtain a qualified appraisal or fails to otherwise meet the \nrequirements of IRC § 170(f)(11)(B),(C), or (D), the deduction is not disallowed \nif the failure was due to reasonable cause and not to willful neglect. IRC § \n170(f)(11)(A)(ii)(II). A determination of whether or not the taxpayer acted \nreasonably and not with willful neglect, requires an analysis of the relevant facts \nand circumstances. If you have any questions or concerns, consult Counsel. \n(2) See Chapter 7 for additional information on qualified appraisals. \nE. Façade Easement Filing Fee (Registered Historic District Only) \n(1) For deductions of more than $10,000, for a donation of an easement on a \nbuilding in a registered historic district, a donor must pay a $500 filing fee with \nits return in the taxable year of the contribution. IRC § 170(f)(13). The fee is to \nbe used to enforce the provisions of IRC § 170(h). \n(2) Payment is transmitted to the IRS using Form 8283-V, Payment Voucher for \nFiling Fee under Section 170(f)(13) (PDF). \nF. Baseline Study \n", "46 \n \n(1) A donor that retains rights in property subject to a donated conservation \neasement (nearly all donors) must make available to the qualified organization \ndocumentation that establishes the condition of the property at the time of the \ngift (baseline study). Treas. Reg. § 1.170A-14(g)(5)(i). The baseline study must \nbe signed by the donor and donee. The baseline study generally includes \nmaps, surveys, and photographs of the property and must be given to the \nqualified organization prior to the time the donation is made. \n(2) See Chapter 5 for additional information on baseline documentation. \nG. Additional Donor Recordkeeping Requirements \n(1) In addition to the substantiation requirements described above, Treas. Reg. § \n1.170A-14(i) requires the donor of a qualified conservation easement who \nclaims a deduction to maintain written records of the FMV of the property before \nand after the donation and the conservation easement purpose furthered by the \ndonation. \nH. Exhibit 6-1 - Substantiation Requirements \nRequired Item \nCriteria \nDue Date \nAttach to Return? \nContemporaneous \nWritten \nAcknowledgment \n \n≥ $250 or more \nEarlier of return filing date \nor due date (with \nextensions) \n \nNo \n \n \nForm 8283 \n(Appraisal \nSummary) \n \n> $500, ≤ $5,000 - \nPart A \n> $5,000 Part B \n \n \nReturn filing date \nYes \nAlso attach \nconservation \neasement \nstatement per Form \n8283 Instructions \n \n \nQualified Appraisal \n \n \n >$5,000 \nMust be made no earlier \nthan 60 days prior to date \nof contribution, but no later \nthan original/amended \nreturn filing date \nYes, but only if > \n$500,000 or an \neasement on a \nbuilding in a \nregistered historic \ndistrict \n \nFaçade Filing Fee of \n$500 \nAll easements on \nbuildings in \nregistered historic \ndistricts >$10,000 \n \nReturn filing date \nNo \nMail in with Form \n8283-V \n", "47 \n \n \n \nBaseline Study \nRequired to be \nmade available to \ndonee and signed \nby donor and donee \nto establish \ncondition of \nproperty \n \n \nBefore time of donation \n \n \nNo \nVII. \n Qualified Appraisal Requirements \nA. Overview \n(1) Generally, noncash charitable contributions for which a deduction of more than \n$5,000 is claimed must be substantiated with a qualified appraisal prepared by \na qualified appraiser in accordance with generally accepted appraisal \nstandards. IRC §§ 170(f)(11)(C) and (f)(11)(E)(i)(II). \n(2) The Pension Protection Act of 2006 (PPA) amended IRC § 170(f)(11)(E) to \nprovide definitions of qualified appraisal and qualified appraiser. See Notice \n2006-96, 2006-2 C.B. 902, for transitional rules. See Treas. Reg. § 1.170A-17 \nfor contributions on or after January 1, 2019. \n(3) Treas. Reg. § 1.170A-13(c)(3), which predates IRC § 170(f)(11)(E), sets forth \nsubstantiation requirements that must be met for the appraisal to be considered \na qualified appraisal. Portions of Treas. Reg. § 1.170A-13(c)(3) are superseded \nby IRC § 170(f)(11)(E). \n(4) This chapter discusses the requirements for a qualified appraisal, a qualified \nappraiser and generally accepted appraisal standards. \n(5) See Publication 561, Determining the Value of Donated Property (PDF), Treas. \nReg. § 1.170A-13 and Treas. Reg. § 1.170A-17 for additional guidance on \nqualified appraisal requirements. \nB. Qualified Appraisal \n(1) Section 170(f)(11) states that no deduction is allowed for any contribution of \nproperty for which a deduction of more than $500 is claimed unless the \nrequirements of IRC § 170(f)(11)(B), (C), and (D) are met. \n(2) Section 170(f)(11)(C) requires a qualified appraisal for property donations of \nmore than $5,000. \n(3) Section 170(f)(11)(D) additionally requires the attachment of the qualified \nappraisal to the return if the deduction claimed exceeds $500,000. \n(4) For contributions of façade easements in registered historic districts, a qualified \nappraisal must be attached regardless of the dollar amount claimed as a \ndeduction. IRC § 170(h)(4)(B)(iii)(I). \n(5) Note: This special rule does not apply to properties listed on the National \nRegister. \n", "48 \n \n(6) Section 170(f)(11)(E) was amended in 2006 to include new definitions of the \nterms “qualified appraisal” and “qualified appraiser.” Treas. Reg. § 1.170A-17 \nprovides guidance relating to these definitions. For contributions prior to \nJanuary 1, 2019, taxpayers may rely on the transitional guidance and safe \nharbors in Notice 2006-96. \n(7) An appraisal is treated as a qualified appraisal within the meaning of IRC § \n170(f)(11)(E) if the appraisal complies with all of the requirements of Treas. \nReg. § 1.170A-17. For contributions prior to January 1, 2019, an appraisal that \ncomplies with all the requirements of Treas. Reg. § 1.170A-13(c) (except to the \nextent the regulations are inconsistent with IRC § 170(f)(11)) is also treated as \na qualified appraisal. See Notice 2006-96. \n(8) A qualified appraisal must: \n• Be prepared, signed and dated by a qualified appraiser in accordance with \ngenerally accepted appraisal standards. \n• Meet the relevant requirements of Treas. Reg. § 1.170A-17(a). \n• Be dated no earlier than 60 days before the date of contribution nor later \nthan: \n• The due date (including extensions) of the tax return on which the \ncharitable contribution deduction is first claimed. \n• In the case of a partnership or S corporation, the due date \n(including extensions) of the return on which the deduction is first \nreported; or \n• In the case of a deduction first claimed on an amended return, the \ndate on which the amended return is filed. \n• Not involve a prohibited appraisal fee, which, in general, means that the \nappraisal fee may not be based on the appraised value of the property. \n(9) Treas. Reg. § 1.170A-17(a)(3) outlines specific items that must be included in a \nqualified report: \n• A detailed description of the property. \n• The property’s physical condition (for a contribution of real property or \ntangible personal property). \n• The date or expected date of the contribution. \n• The valuation effective date, defined in Treas. Reg. § 1.170A-17(a)(5). \n• The terms of any agreement relating to the property’s use, sale or other \ndisposition. \n• The appraiser’s name, address, and taxpayer identification number, and \nthat of the appraiser’s employer or partnership. \n", "49 \n \n• The qualifications of the appraiser, including the appraiser’s background \nexperience, education and membership in professional appraisal \nassociations. \n• A statement that the appraisal was prepared for income tax purposes. \n• The signature of the appraiser and the date signed by the appraiser. \n• The declaration by the appraiser set forth in Treas. Reg. § 1.170A-\n17(a)(3)(vi). \n• The appraised FMV of the property on the valuation effective date. \n• The method of valuation used to determine the FMV. \n• The specific basis for the valuation (such as specific comparable sales \ntransactions or statistical sampling, including a justification for using \nsampling and an explanation of the sampling procedure used). \n(10) \nAn appraisal is not a qualified appraisal for a particular contribution if the donor \neither failed to disclose or misrepresented facts, and a reasonable person \nwould expect that this failure or misrepresentation would cause the appraiser to \nmisstate the value of the donated property. Treas. Reg. § 1.170A-17(a)(6). \n(11) \nNote that for contributions made before January 1, 2019, Treas. Reg. § 1.170A-\n13(c)(5)(ii) states that an individual is not a qualified appraiser with respect to a \nparticular donation if the donor had knowledge of facts that would cause a \nreasonable person to expect the appraiser falsely to overstate the value of the \ndonated property. \n(12) \nSee also Notice 2006-96, which provides guidance and safe harbors that \ntaxpayers can rely on for contributions prior to January 1, 2019. \n(13) \nAudit Tip: Examiners must ensure that the appraisal describes exactly what is \nbeing donated, an easement, and not a going concern and/or mineral or \nproperty rights. In Costello v. Commissioner, T.C. Memo. 2015-87, the \nappraisal did not describe or purport to value an easement. Rather, it stated \nthat “the property rights appraised comprise the fee simple interest in the \nsubject property.” For that and other reasons, the tax court concluded that the \nappraisal was not a qualified appraisal under sec. 1.170A-13(c)(3)(i), the \npredecessor of the currently applicable -17 regs. \n(14) \nAudit Tip: Examiners should also consider whether the appraiser failed to \nconsider and analyze prior transfers of the properties. Generally, the appraisals \nshould mention prior transfers and try and reconcile any discrepancy in value. \nB.1. Reasonable Cause Exception \n(1) The charitable contribution deduction will not be denied for the donor’s failure to \ncomply with the requirements of IRC § 170(f)(11) if the failure was due to \nreasonable cause and not willful neglect. IRC § 170(f)(11)(A)(ii)(II). Reasonable \n", "50 \n \ncause requires that the taxpayer exercise ordinary business care and prudence \nas to the challenged item, and thus the inquiry is inherently a fact-intensive one. \n(2) A taxpayer’s reliance on the advice of a professional constitutes reasonable \ncause and not willful neglect if the taxpayer can prove by a preponderance of \nthe evidence that: (1) the taxpayer reasonably believed the professional was a \ncompetent tax adviser with sufficient expertise to justify reliance; (2) the \ntaxpayer provided necessary and accurate information to the advising \nprofessional; (3) the taxpayer actually relied in good faith on the professional’s \nadvice. These determinations are very fact-specific. Compare Crimi v. \nCommissioner, T.C. Memo. 2013-51 (donor met the reasonable cause \nrequirements) with Alli v. Commissioner, T.C. Memo. 2014-15 (donor did not \nmeet the reasonable cause requirements). \nC. Qualified Appraiser \n(1) The term “qualified appraiser” as defined in IRC § 170(f)(11)(E)(ii) means an \nindividual who: \n• Has earned an appraisal designation from a recognized professional \nappraiser organization or met minimum education and experience \nrequirements as set forth in the regulations, \n• Regularly performs appraisals for which the individual receives \ncompensation, and \n• Meets such other requirements as prescribed by the Secretary in \nregulations or other guidance. \n(2) An individual is not a qualified appraiser unless the individual: \n• Demonstrates verifiable education and experience in valuing the type of \nproperty subject to the appraisal, and \n• Has not been prohibited from practicing before the IRS any time in the 3-\nyear period ending on the date of the appraisal. IRC § 170(f)(11)(E)(iii). \n(3) Treas. Reg. § 1.170A-17 provides guidance on the qualified appraiser \nrequirements. \n• If the appraiser is relying on an appraisal designation to meet the \neducation and experience requirements in Treas. Reg. § 1.170A-17(b)(2), \nthe designation from a recognized appraiser organization must be based \non the appraiser’s demonstrated competency. \n• The appraiser is treated as having demonstrated education and \nexperience in valuing the type of property that is “verifiable” within the \nmeaning of IRC § 170(f)(11)(E)(iii) and Treas. Reg. § 1.170A-17(b)(4) if \nthe appraiser specifies, in the appraisal, the appraiser’s education and \nexperience in valuing the type of property and the appraiser makes a \ndeclaration in the appraisal that, because of the appraiser’s experience \n", "51 \n \nand education the appraiser is qualified to make appraisals of the type of \nproperty being valued. \n(4) Under Treas. Reg. § 1.170A-17(b)(5)(v)(C), an independent contractor who is \nregularly used as an appraiser by any of the individuals described in Treas. \nReg. § 1.170A-17(b)(5) (ii), (iii), or (iv) and who does not perform a majority of \nhis or her appraisals for others during the taxable year is not a qualified \nappraiser. In the syndicated conservation easement context, it may come to the \nattention of the Tax Matters Partner or others that the appraiser may have \nviolated this provision because of his/her repetitive dealings with the facilitators \nof the transaction. Examiners should contact Counsel to discuss whether an \nappraiser’s conduct is contrary to Treas. Reg. § 1.170A-17(b). \n(5) Also, an individual who is prohibited from practicing before the Internal Revenue \nService under 31 U.S.C. 330(c) (now 31 U.S.C. 330(d)) at any time during the \nthree-year period ending on the date the appraisal is signed by the individual is \nnot a qualified appraiser. Treas. Reg. § 1.170A-17(b)((5)(vi). \n(6) A qualified appraisal must include the appraiser’s qualifications to value the \ntype of property being valued. Treas. Reg. § 1.170A-17(a)(3)(iii)(B). The \nappraiser’s resume, which is typically included in the appraisal, may be included \nto satisfy this requirement and provides a good starting point to assess whether \nthe appraiser is a qualified appraiser. The resume provides information on his \nor her education and experience and professional designations. It will also \ntypically indicate in which jurisdictions the appraiser holds a license or \ncertification. \n(7) License information regarding jurisdictions, history, and disciplinary actions can \nbe found on The Appraisal Foundation Web page at \nhttp://www.appraisalfoundation.org. Some states also provide appraisal \nlicensing information online. Examiners or IRS appraisers can contact the \nvarious state boards by telephone to determine if there are any past or pending \ndisciplinary actions against the appraiser. The Office of Professional \nResponsibility (OPR) publishes a list of practitioners, including appraisers, who \nhave been subject to disciplinary actions by the IRS. \nD. Generally Accepted Appraisal Standards \n(1) Section 170(f)(11)(E)(i)(II) and Treas. Reg. § 1.170A-17 state that a qualified \nappraisal is an appraisal conducted by a qualified appraiser in accordance with \ngenerally accepted appraisal standards and any regulations or other guidance \nprescribed by the Secretary. \n(2) Treas. Reg. § 1.170A-17(a)(2) provides that “generally accepted appraisal \nstandards” means the substance and principles of the Uniform Standards of \nProfessional Appraisal Practice (USPAP), as developed by the Appraisal \nStandards Board of The Appraisal Foundation. \nD.1. Uniform Standards of Professional Appraisal Practice \n", "52 \n \n(1) In 1989, The Appraisal Foundation, a nonprofit organization, adopted licensing \nand appraisal standards for the appraisal industry. USPAP sets forth the \nminimum acceptable appraisal standards for federally regulated transactions. \nUSPAP is recognized throughout the U.S. as the generally accepted standards \nof professional appraisal practice. \n(2) Although USPAP was intended for appraisals prepared for federally regulated \ntransactions, all states have adopted USPAP for real estate appraisals \ncompleted by licensed or certified appraisers. \n(3) In addition, various appraisal organizations such as the Appraisal Institute (AI), \nNational Association of Independent Fee Appraisers (NIAFA), American Society \nof Appraisers (ASA), and American Society of Farm Managers and Rural \nAppraisers (ASFMRA) have additional standards and ethics that their \nmembership (both designated and undesignated) is required to follow. For the \nmost part these organizations require adherence to USPAP. \n(4) For contributions prior to January 1, 2019, IRC § 170(f)(11)(E)(i)(II) does not \nspecifically mandate compliance with USPAP but does require the appraisal to \nbe prepared in accordance with generally accepted appraisal standards. Notice \n2006-96, section 3.02(2). Qualified real estate appraisers holding themselves \nout to the public as appraisers generally would be required to comply with \nUSPAP by virtue of their appraisal licenses and professional designations. For \ncontributions on or after January 1, 2019, Treas. Reg. § 1.170A-17(a)(1) and (2) \nrequire that appraisals be prepared in accordance with the substance and \nprinciples of USPAP. \n(5) In assessing whether an appraisal is a qualified appraisal, Examiners and IRS \nAppraisers must consider whether the appraisal is prepared in accordance with \nthe substance and principles of USPAP. If not, it is not a qualified appraisal \nunder Treas. Reg. § 1.170A-17(a), which is applicable to contributions made on \nand after January 1, 2019. For rules applicable to contributions made before \nJanuary 1, 2019, see IRC § 170(f)(11)(E) and Notice 2006-96. \n(6) The USPAP rules of ethics provide that “[a]n appraiser must perform \nassignments with impartiality, objectivity, and independence, and without \naccommodation of personal interests. Further, it provides that, among other \nthings, an appraiser “must not perform an assignment with bias; must not \nadvocate the cause or interest of any party or issue; must not accept an \nassignment that includes the reporting of predetermined opinions and \nconclusions;… must not communicate assignment results with the intent to \nmislead or to defraud;…[and] must not use or communicate a report or \nassignment results known by the appraiser to be misleading or fraudulent…” \nThere may be grounds to challenge whether the appraisal is a qualified \nappraisal if any of the above (or other improper conduct) is present. Examiners \nshould consult Counsel regarding these issues. \n(7) Audit Tip: Examiners should work with the IRS Appraisers to consider whether \nthe appraiser complied with USPAP in substance. For example, Examiners \n", "53 \n \nshould consider whether the appraiser used “extraordinary assumptions” and/or \nimproper “hypothetical conditions” as the basis for the appraisal. \n(8) Audit Tip: Examiners may consider, in assessing whether the appraiser \nsatisfies the USPAP rules, the pattern of conduct between the appraiser and \nthe promoter/managing member of a partnership. For example, an appraiser’s \npattern of providing inflated appraisals to a promoter in other transactions may \nsuggest that the appraiser did not act independently in the transaction under \naudit. If pattern evidence will form the basis for a position in any written \ndocument to the taxpayer, it should be coordinated with Counsel. \nE. Appraisal Fees \n(1) Appraisal fees that a taxpayer pays to determine the FMV of donated property \nare not deductible as charitable contributions. However, for taxable years prior \nto 2018, taxpayers can claim appraisal fees, subject to the two percent of \nadjusted gross income (AGI) limit, as a miscellaneous itemized deduction on \nSchedule A, Itemized Deductions (PDF), of Form 1040, U.S. Individual Income \nTax Return (PDF). Beginning in taxable year 2018, appraisal fees paid to \ndetermine the FMV of donated property are not deductible as miscellaneous \nitemized deductions on Schedule A. \nVIII. Amount of Deduction \nA. Overview \n(1) There are several considerations that may influence the amount a taxpayer may \nclaim as a charitable contribution deduction for a conservation easement. \nThese considerations may be categorized as follows: \n• FMV (See Chapter 9) \n• Percentage limitations \n• Carryovers \n• Contributions of appreciated property (ordinary income, short-term capital \ngain, long-term capital gain) \n• Bargain sale \n• Quid pro quo or substantial benefit and charitable intent \nB. Percentage Limitations \nB.1. Individuals \n(1) For charitable contributions by individuals, the amount of the deduction a \ntaxpayer may claim is subject to a limitation based on a percentage of that \ntaxpayer’s “contribution base.” IRC § 170(b)(1)(H). This limitation is referred to \nas a percentage limitation. Percentage limitations may vary, depending on: \n• The type of property donated, \n", "54 \n \n• The type of qualified donee organization that received the donation, and \n• The use of the property by the qualified donee organization. \n(2) Contribution base for individuals is defined in IRC § 170(b)(1)(H) as the \nindividual’s adjusted gross income (computed without regard to any net \noperating loss carryback to the taxable year under IRC § 172). \n(3) See Publication 526, Charitable Contributions (PDF) for additional guidance on \npercentage limitations. \n(4) In general, when an individual contributes to an organization described in IRC § \n170(b)(1)(A) (IRC § 170(b)(1)(A) organization), that individual’s deduction may \nnot exceed 50% of the individual’s “contribution base.” IRC § 170(b)(1)(A). \n(5) When the individual contributes long-term capital gain property to an IRC § \n170(b)(1)(A) organization, however, the applicable percentage limitation may be \nlimited to 30% of the individual’s contribution base. IRC § 170(b)(1)(C). \n(6) A deduction arising from an individual’s contribution to a qualified, but otherwise \nnon-IRC§ 170(b)(1)(A) organization may not exceed 30% of the individual’s \ncontribution base. IRC § 170(b)(1)(B). When that contribution is of long-term \ncapital gain property, a percentage limitation of 20% may apply instead. IRC § \n170(b)(1)(D). \n(7) A conservation easement is considered long-term capital gain property if the \nunderlying property is a capital asset held for more than a year. Generally, \nwhen an individual contributes a qualified conservation contribution, the \nindividual’s deduction for that contribution may not exceed 50% of his or her \n“contribution base.” IRC § 170(b)(1)(E)(i). \n(8) If the individual is a qualified farmer or rancher, however, a 100% limitation may \napply. IRC § 170(b)(1)(E)(iv). \n(9) The maximum percentage limitation for contributions of cash by individuals is \n50% for contributions made in tax years beginning before January 1, 2018, and \nis increased to 60% for contributions of cash made in tax years beginning after \nDecember 31, 2017, and 100% for contributions of cash in 2020. \nB.2. Corporations \n(1) For C-corporation donors, in general, the maximum amount allowable as a \ncharitable contribution deduction for any taxable year is 10% of that \ncorporation's taxable income for that year (25% for 2020), computed with \ncertain adjustments described in IRC § 170(b)(2)(D). \nB.3. Special Rules for Qualified Farmers and Ranchers \n(1) In general, if an individual is a “qualified farmer or rancher” and makes a \nqualified conservation contribution of “property used in agriculture or livestock \nproduction,” the qualified farmer or rancher may claim a charitable contribution \n", "55 \n \ndeduction up to 100% of the contribution base. IRC § 170(b)(1)(E)(iv). See and \nIRC § 170 (b)(2)(B) for corporate farms and ranchers. \n(2) A “qualified farmer or rancher” is generally an individual or corporate taxpayer \nwhose gross income from the trade or business of farming is greater than 50% \nof that taxpayer’s gross income for the taxable year. IRC § 170(b)(1)(E)(v). \nGross income from the trade or business of farming does not include income \nfrom the sale of property. Rutkoske v. Commissioner, 149 T.C. 133 (2017). \n(3) A qualified conservation contribution is of “property used in agriculture or \nlivestock production” only when the contribution subjects the underlying \nproperty to a restriction that requires the property to remain available for \nagriculture or livestock production. IRC § 170(b)(1)(E)(iv)(II). If the contribution \nfails to do so, the ordinary limitations for qualified conservation contributions will \napply. \nB.4. Carryovers \n(1) In general, taxpayers (both individuals and corporations) can carry over unused \ncharitable contributions for up to five years. For conservation easement \ncontributions, however, the carryover period is 15 years. IRC § 170(b)(2)(E) and \n(2)(B)(ii). \nC. Contributions of Appreciated Property \n(1) Generally, a taxpayer’s deduction for a charitable contribution of property \nequals the FMV of the property, but in some cases it may be limited to the \nlesser of FMV or basis. \n(2) If a taxpayer contributes appreciated property (i.e., property with a FMV that \nexceeds the taxpayer's basis), the amount of the taxpayer’s charitable \ncontribution deduction may be reduced. As relevant here, the extent to which a \ntaxpayer’s deduction may be reduced will depend on the nature of the \ncontributed property. IRC § 170(e)(1). To determine whether to reduce the \namount of allowable deduction, find out whether the property is: \n• Ordinary income property \n• Short-term capital gain property \n• Long-term capital gain property \n(3) See Publication 544, Sales and Other Dispositions of Assets (PDF) for \nadditional guidance. \nC.1. Ordinary Income and Short-Term Capital Gain Property \n(1) Generally, if the property is ordinary income property or short-term capital gain \nproperty, the taxpayer’s deduction is limited to basis. IRC § 170(e)(1)(A). \n(2) This rule applies to contributions of appreciated property only to the extent that, \nif the taxpayer had hypothetically sold the property for FMV rather than donate \n", "56 \n \nthe property, the resulting gain would have been ordinary income or short-term \ncapital gain to the taxpayer. \n(3) This means that, generally, if the property is ordinary income property in the \nhands of the donor-taxpayer, the taxpayer’s deduction is limited to basis. \n(4) An example of ordinary income property is inventory. In a real property context, \ninventory will include real property (land and anything built on it) held by a real \nestate dealer, when that real property is primarily held for sale to the dealer’s \ncustomers in the ordinary course of his/her trade or business. \n(5) Gain on the disposition of depreciable real property is treated as ordinary \nincome to the extent of additional depreciation allowed or allowable on the \nproperty. Additional depreciation is the amount of the actual depreciation over \nthe depreciation figured using the straight line method. See Publication 544, \nSales and Other Disposition of Assets (PDF) and Form 4797 (PDF) and the \nrelated instructions. \n(6) Contributions of short-term capital gain property (such as real estate held for \ninvestment for a year or less) is treated the same as ordinary income property \nin that the taxpayer’s deduction is generally limited to basis. \n• Example: Jefferson contributes a conservation easement on a parcel that \nhe held for 11 months. The conservation easement is short-term capital \ngain property, and Jefferson's deduction is limited to the lesser of his basis \nin the easement or its FMV. \n(7) The amount of basis allocable to the conservation easement bears the same \nratio to the total basis of the property as the FMV of the conservation easement \nbears to the FMV of the entire parcel before the granting of the conservation \neasement. IRC § 170(e)(2); Treas. Reg. § 1.170A-4(c). \n• Example: Mary paid $80,000 for a parcel held for investment, which has a \nFMV of $100,000. She decides to donate a conservation easement with a \nFMV of $5,000. If Mary's parcel is held for less than one year, her \ndeduction for the easement is $4,000 ($5,000/$100,000 x $80,000 = \n$4,000). If Mary held the property for more than a year, her deduction is \nthe easement's FMV ($5,000). \nC.2. Long-Term Capital Gain Property \n(1) If the taxpayer contributes appreciated long-term capital gain property, the \ntaxpayer’s deduction generally is not limited to basis and may equal FMV. IRC \n§ 170(e)(1). \n(2) Property is long-term capital gain property when, if the taxpayer had \nhypothetically sold the property or FMV rather than donated the property, its \nsale on the date of the contribution would have resulted in long-term capital \ngain to the taxpayer. \n", "57 \n \n(3) Long-term capital gain property is a capital asset held for more than a year. IRC \n§ 1222(3). \n(4) Examples of long-term capital gain property are (1) real estate held for more \nthan a year for investment, or (2) a personal residence held for more than a \nyear. \nD. Bargain Sale \n(1) A bargain sale is a taxpayer’s sale or transfer of property to a qualified \norganization for less than the property's FMV. Treas. Reg. § 1.170A-4(c)(2)(ii). \n(2) A bargain sale is treated partly as a charitable contribution and partly as a sale \nor exchange of the property. As such, to qualify for bargain sale treatment, the \ntaxpayer must establish that charitable intent motivated the taxpayer to sell the \nproperty to the qualified organization for less than FMV. \n(3) As relevant here, the amount of the charitable contribution deduction arising \nfrom the bargain sale equals the excess of the FMV of the property less the \nconsideration paid by the qualified organization to acquire the property. \n• Example: Betty sells a conservation easement (on property held for \ninvestment for more than one year) to a conservation organization for \n$10,000. The FMV of the easement is $12,500. Her charitable contribution \ndeduction from the bargain sale is $2,500 ($12,500 - $10,000) provided \nthat all requirements to claim a conservation easement deduction have \nbeen met and she knew, at the time of the sale, that the easement was \nworth $12,500. If a taxpayer contributes property subject to a debt (such \nas a mortgage), and the debt is assumed by the qualified organization, the \ntaxpayer must reduce the FMV of the property by the amount of the debt. \nD.1. Taxable Gain \n(1) The part of the bargain sale that is a sale or exchange may result in a taxable \ngain. The amount of taxable gain is determined by allocating basis (under IRC § \n1011(b)) between the portion of the property deemed sold and the portion of \nproperty deemed contributed. \n(2) For more information on determining the amount of any taxable gain, see \n\"Bargain Sales to Charity\" in Publication 544, Sales and Other Dispositions of \nAssets (PDF), and IRC § 1011(b). There are examples in Pub. 544 and Pub. \n526. \n(3) See Treas. Reg. §§ 1.170A-4(c)(2) and 1.170A-14(h)(3)(iii) for additional \nguidance on allocating basis. \nD.2. Federal and State Easement Purchase Programs \n(1) Many states and some federal agencies have conservation easement purchase \nprograms. The purchase price may be at FMV or at a discounted price, \ndepending on the specific program. If the conservation easement was \n", "58 \n \npurchased by the state or federal agency at FMV, then there would be no \ncharitable contribution for the conservation easement. \n(2) The donation must meet all of the statutory and regulatory requirements for a \nqualified conservation easement contribution in order for the taxpayer to claim a \nnoncash charitable contribution for the donation portion of a bargain sale. \nE. Quid Pro Quo or Substantial Benefit and Charitable Intent \n(1) Charitable intent generally exists if the transfer was made without the receipt of, \nor the expectation of receiving, a quid pro quo or substantial benefit for the \ntransfer. As a general rule, if the benefits received or expected to be received \nare greater than those that inure to the general public, the transfer does not \nsatisfy the charitable intent requirement under IRC § 170. Hernandez v. \nCommissioner, 490 U.S. 691 (1989); United States v. American Bar \nEndowment, 477 U.S. 105, 118 (1986); Singer Co. v. U.S., 196 Ct. Cl. 90, 449 \nF.2d 413, 422-423 (1971). \n(2) If the donor receives, or can reasonably expect to receive, a substantial \nfinancial or economic benefit, but it is clearly shown that the benefit is less than \nthe amount of the donor’s transfer, then a deduction is allowable for the excess \nof the amount the donor transferred over the amount of the financial or \neconomic benefit received or reasonably expected to be received by the donor. \nIn considering whether the taxpayer had any expectation of receiving a quid pro \nquo, we may look to external features of the transaction. Triumph Mixed Use \nInvestments III, LLC v. Commissioner, T.C. Memo. 2018-065. The benefits that \nthe taxpayer expects to receive may flow from property that is not the subject of \nthe easement. Wendell Falls v. Commissioner, T.C. Memo. 2018-45. \n(3) If a taxpayer transfers a conservation easement with the expectation of \nreceiving a state or local tax credit in return, that credit is a quid pro quo. See \nTreas. Reg. § 1.170A-1(h)(3), which applies to property transferred by \ntaxpayers after August 27, 2018. \n• Example 1: Steven is a real estate developer. He contributes a \nconservation easement with the expectation that it will result in his \nreceiving preferential zoning treatment from the city zoning board. Steven \nis not allowed a charitable contribution deduction. \n• Example 2: Jeanie lives along a scenic highway. In order for her to secure \na variance on her property, the zoning board requires an easement on 10 \npercent of her property. Jeanie decides to place an easement on 25 \npercent of her property. Jeanie may deduct as a charitable contribution the \nvalue of the easement she placed on 15 percent of her property. \nF. Rehabilitation Tax Credit \n(1) Section 47 is an investment tax credit intended to encourage rehabilitation of \nhistoric buildings for urban and rural revitalization. The rehabilitation tax credit is \n", "59 \n \na 20% credit available to taxpayers who make qualified rehabilitation \nexpenditures with respect to certified historic structures. \n(2) NPS and the IRS in partnership with State Historic Preservation Offices jointly \nadminister the Historic Preservation Tax Incentives Program. See the \nRehabilitation Tax Credit Market Segment Specialization Program Guide (PDF) \nfor additional information. \nF.1. Recapture of Rehabilitation Tax Credit \n(1) Section 50(a)(1) provides for recapture of the investment tax credit upon \ndisposition. \n(2) When a façade easement is contributed during the same year that a qualified \nrehabilitated building is placed in service, the taxpayer will not be entitled to \nclaim the portion of the rehabilitation tax credit attributable to the façade \neasement. Rome I, Ltd. v. Commissioner, 96 T.C. 697 (1991); Rev. Rul. 89-90, \n1989-2 C.B. 3. \n(3) Under IRC § 50, if a taxpayer claims a rehabilitation tax credit with respect to \nproperty and subsequently makes a qualified conservation contribution (i.e., \ncontributes a façade easement) with respect to the property, the charitable \ncontribution is a partial disposition of the property. This event will trigger \nrecapture of all or part of the credit if the contribution is made within the \nrecapture period (5 years from the placed in service date). See Rev. Rul. 89-90. \n(4) Pursuant to IRC § 170(f)(14), the amount of a taxpayer’s charitable contribution \ndeduction for a qualified conservation contribution may be reduced if the \ntaxpayer was allowed IRC § 47 credits for prior years with respect to the \nbuilding underlying the present conservation contribution. In such cases, the \namount of the taxpayer’s deduction will be reduced by an amount bearing the \nsame ratio to the FMV of the contribution as the sum of the total IRC § 47 \ncredits allowed to the taxpayer for the 5 preceding years over the FMV of the \nbuilding on the date of contribution. \n(5) See the Rehabilitation Tax Credit Market Segment Specialization Program \nGuide (PDF) for additional information. \nIX. Valuation of Conservation Easements \nA. Overview \n(1) To determine the FMV of a conservation easement, appraisers must have a \nclear understanding of IRC § 170 and the accompanying Treasury regulations. \nThe appraiser also must meet the definition in IRC § 170(f)(11)(E) of a “qualified \nappraiser.” \n(2) The value of a conservation easement is the FMV at the time of contribution \nand depends on the particular facts and circumstances of the property. Treas. \nReg. § 1.170A-14(h)(3)(i). \n", "60 \n \n(3) Section 170(f)(11)(E) and Treas. Reg. § 1.170A-13(c)(3) impose substantiation \nrequirements that must be met for the appraisal to be considered a qualified \nappraisal. \n(4) Treas. Reg. § 1.170A-14(h)(3)(i) requires that, if there is a substantial record of \nsales of comparable easements, those sales are used to value conservation \neasements. Since easements are not typically sold, there usually are \ninsufficient sales to use a comparable easement sales approach. In most \ncases, the \"before and after\" method of valuing a conservation easement is \nused. \n(5) The purpose of this chapter is to provide a general overview on the valuation of \nconservation easements and generally accepted appraisal standards. A \ncomprehensive discussion of valuation is beyond the scope of this ATG. \n(6) See Treas. Reg. §§ 1.170A-13 and 1.170A-14, and, for contributions on or after \nJanuary 1, 2019, Treas. Reg. 1.170A-17. See also Notice 2006-96, Publication \n526, Charitable Contributions (PDF), Publication 561, Determining the Value of \nDonated Property (PDF), Form 8283, Noncash Charitable Contributions (PDF), \nand the Instructions for Form 8283 (PDF) for more information about valuation, \nqualified appraisers, qualified appraisals, and other requirements. \nB. Valuation Process \n(1) Valuation, as defined by the Dictionary of Real Estate Appraisal, Sixth Edition, \nThe Appraisal Institute, Chicago, Ill., 2015, is the process of estimating the FMV \nof an identified interest in a specific parcel or parcels of real estate as of a \nspecified date. It is a term used interchangeably with appraisal. The valuation \nprocess includes: \n• Defining the problem/scope of work, \n• Data collection and property description, \n• Data analysis, \n• Application of the approaches to value, \n• Reconciliation of value indications and final opinion of value, and \n• Reporting the defined value. \n(2) Critical to the completion of any valuation assignment, especially the valuation \nof a conservation easement, is clearly defining the problem and determining the \nscope of work. A detailed scope of work should be presented in the appraisal to \nallow a reader to understand exactly what steps and procedures were utilized \nby valuation experts in their analyses and FMV determinations. \n(3) Appraisers must have a thorough understanding of which rights were “given up” \nor relinquished and which rights were retained by the donor in order to properly \nvalue the conservation easement. They must refer to the deed to determine \nwhat rights were relinquished. \n", "61 \n \nC. Valuation Date \n(1) The value of a conservation easement contribution is the FMV of the easement \nat the time of the contribution. Treas. Reg. § 1.170A-14(h)(3)(i). For federal \nincome tax purposes, the date of contribution is the date the deed of easement \nis recorded pursuant to state law. The qualified appraisal must state, among \nother things, the date or expected date of the contribution. Treas. Reg. § \n1.170A-13(c)(3)(ii)(C); Treas. Reg. § 1.170A-17(a)(3)(iii). \nD. FMV \n(1) The value of the donated easement must meet the definition of FMV as defined \nby Treas. Reg. § 1.170A-1(c)(2): \n• The FMV is the price at which the property would change hands between \na willing buyer and a willing seller, neither being under any compulsion to \nbuy or sell and both having reasonable knowledge of relevant facts. \n(2) A common error found in appraisals submitted for federal income tax purposes \nis that the FMV definition utilized in the appraisals is not correct. Also, the FMV \nof the property must decrease as a result of the granting of the conservation \neasement in order for a taxpayer to claim a charitable contribution deduction. In \nsome instances, the grant of a conservation easement may have no material \neffect on the value of the property or may in fact serve to enhance the value of \nproperty. Treas. Reg. § 1.170A-14(h)(3)(ii). \nD.1. Before and After Method \n(1) In theory, the best evidence of FMV of a conservation easement is the sale \nprice of easements comparable to the donated easement. An appraiser should \nresearch the market to determine if there is a substantial record of sales of \ncomparable easements; however, in most instances, there is no substantial \nrecord of comparable sales. \n(2) If there is no substantial record of comparable easement sales, the \"before and \nafter\" approach to valuing a conservation easement is used. \n• FMV of the property before the easement – FMV of the property after the \neasement = FMV of the easement \n(3) In essence, an appraiser must determine the highest and best use (HBU) and \nthe corresponding FMV of the subject property twice: first, without regard to the \nconservation easement (“before” value), and then again after considering the \nspecific restrictions imposed on the property by the deed (“after” value). \n(4) In determining the “before” value of the property, an appraiser must consider \nthe current use of the property but also objectively assess the likelihood that the \nproperty would be developed absent the conservation easement restriction. \nExisting zoning, conservation, historic preservation, or other laws and \n", "62 \n \nrestrictions may limit the property’s potential HBU. Treas. Reg. § 1.170A-\n14(h)(3)(ii). \n(5) In determining the “after” value of the property, an appraiser must consider both \nthe specific restrictions imposed by the conservation easement being valued \nand the specific restrictions imposed by easements on any “comparable” \nproperties. \nD.2. Use of Flat Percentage Cannot Be Applied to Before Value \n(1) There is no standard value or percentage impact on the “before” value of the \nproperty due to the granting of a conservation easement. Each conservation \neasement must be valued before and after the granting of the easement, based \non the particular facts and circumstances of that property, and the value must \nbe substantiated with a qualified appraisal. \nD.3. Contiguous Parcels \n(1) The amount of the charitable contribution deduction due to the granting of a \nconservation easement covering a portion of a contiguous property owned by \nthe donor and the “donor’s family” (as defined in IRC § 267(c)(4)) is the \ndifference between the FMV of the entire contiguous parcel of the property \nbefore and after the granting of the easement. Treas. Reg. § 1.170A- \n14(h)(3)(i). \n(2) Section 267(c)(4) defines the term “family” as including only an individual’s \n“brothers and sisters (whether by the whole or half-blood), spouse, ancestors \nand lineal descendants.” Parents, children, grandparents, grandchildren, half-\nbrothers and half-sisters are included in the definition of family, but cousins, \nnieces, nephews, in-laws, and step relations are not included. \n• Example: John Smith owns a 1,000-acre farm. Mr. Smith decides to put a \nconservation easement on the southern 500 acres. The entire 1,000 acres \nwould need to be valued before and after the easement is imposed \nbecause the donor owns the entire 1,000 acres, and the unencumbered \nparcel is contiguous to the encumbered parcel. \n(3) In order to properly determine what properties should be valued, an appraiser \nmust identify and determine the ownership of any contiguous parcels at the \noutset of the appraisal assignment. Next, the appraiser must assess whether \nthe owners of any contiguous parcels are the donor or donor’s family as defined \nin IRC § 267(c)(4). \n(4) Application of the contiguous parcel rules can be complex. IRS appraisers \nshould contact a program analyst or Counsel for guidance. For information \nabout contiguous parcels, see CCA 201334039 (8/23/2013). \nD.4. Enhancement Rule \n", "63 \n \n(1) A taxpayer must also consider any enhancement to the value of other property \nowned by the donor or a “related person” resulting from the taxpayer’s \ncontribution of a conservation easement. The amount of the conservation \ncontribution deduction is reduced by the amount of the increase in the value of \nthe other property, whether or not that other property is contiguous. Treas. Reg. \n§ 1.170A- 14(h)(3)(i). \n(2) A related person, for purposes of applying the enhancement rule, is defined in \nIRC §§ 267(b) or 707(b). Application of the related party rules can be complex. \nIRS appraisers should contact a program analyst or Counsel for guidance. \n(3) There are two important distinctions between the contiguous parcel and the \nenhancement rules. First, the contiguous parcel rule applies only to contiguous \nproperty, but the enhancement rule can apply to both contiguous and \nnoncontiguous property. Second, the contiguous parcel rule only applies to \ncontiguous property owned by the donor or the donor’s family (as defined in \nIRC § 267(c)(4)), but the enhancement rule applies to contiguous or \nnoncontiguous property owned by a related party under §§ 267(b) or 707(b). \nThe definition of “related person” includes the donor’s family members and also \n“related” non-family members. \n• Example: John Smith owns a 1,000-acre farm. Mr. Smith decides to put a \nconservation easement on the southern 500 acres. The entire 1,000-acre \nparcel would need to be valued based on the application of the contiguous \nparcel rule. John Smith also owns a noncontiguous 50-acre parcel located \nwithin a quarter mile of the subject property. Because of the conservation \neasement, the 50-acre parcel will have superior views of the river that lies \nbeyond the 500-acre parcel. As a result, the 50-acre parcel would need to \nbe valued and the conservation easement contribution would be reduced \nby the amount of the increase in value (if any) to the 50-acre parcel. \n(4) Application of the enhancement rules can be complex. IRS appraisers should \ncontact a program analyst or Counsel for guidance. See CCA 201334039 \n(8/23/2013). \nE. Market Analysis \n(1) Market analysis is defined as a process for examining the demand for and \nsupply of a property type and the geographic market area for that property type. \nThis is a critical step in the highest and best use analysis. The six-step market \nanalysis process described below provides data required for the four test \ncriteria (physically possible, legally permissible, financially feasible and \nmaximally productive). See The Appraisal of Real Estate, 14th Edition, The \nAppraisal Institute, Chicago, Ill., 2013, page 299. \n(2) An appraiser can use current and historical market conditions to infer future \nsupply and demand. In addition, to forecast subject-specific supply, demand, \nabsorption and capture rate (capture rate is the percentage of total market \ndemand a specific property or group of properties is expected to capture) over a \n", "64 \n \nproperty’s projected holding period, the appraiser should augment the analysis \nof current and historical market conditions with fundamental analysis. Given the \nfact that, in the majority of conservation easement cases, development of the \nproperty has not taken place, then there should be more emphasis on a \nfundamental analysis. A fundamental analysis would require an analysis of \nhistoric and projected: population, income, zoning, demand, absorption, supply, \nideal improvement, existing space, proposed space, occupied space, market \ndemographics, market income and expense information, capitalization rates, \netc. to forecast future market conditions and is a much more detailed analysis \nthan an inferred analysis. \n(3) Most market analysis can be performed using a six-step process: \n• Property Productivity Analysis: Physical, Legal and Location Attributes \n• Market Delineation: Competitive Market Area \n• Demand Analysis: Demand Segmentation, Historical Growth & Demand \nDrivers \n• Supply Analysis: Existing, Under Construction and Proposed Competition \n• Interaction of Supply and Demand: Competitive and Residual Demand \n• Forecast Subject Capture: Reconciliation of Inferred and Fundamental \nForecasts \n(4) Layman’s terms: The appraiser analyzes how competitive the subject property \nis or will be in its market area. The current and future demand for similar \nproperties is estimated and compared to the estimated current and future \nsupply within the market area. \n(5) Appraisers using a residential subdivision method may not always adequately \nquantify the market demand and supply for the proposed lots and/or houses. \nThe Appraisal of Real Estate, 14th Edition, The Appraisal Institute, Chicago, Ill, \n2013, pages 299 – 330 (Chapter 15) provides a detailed discussion on \ncompleting a market analysis for a variety of property types and serves as a \ngood reference tool. \n(6) When appraisers fail to follow the six-step process, and do not support demand, \nsupply and a capture rate for the subject property, it can lead to erroneous \nconclusions in the highest and best use analysis. \nF. Highest and Best Use \n(1) The determination of the property’s HBU is vital to the valuation of any real \nestate, including conservation easements. \n(2) All professional appraisal organizations recognize that the HBU of the property \nis a key element to a proper valuation. To qualify as the HBU, a use must \nsatisfy four criteria: \n", "65 \n \n• Physically Possible - The land must be able to accommodate the size \nand shape of the ideal improvement: What uses of the subject site are \nphysically possible? \n• Legally Permissible - A property use that is either currently allowed or \nmost probably allowable under applicable laws and regulations. What \nuses of the subject site are permitted by zoning, deed restrictions, and \ngovernment restrictions? \n• Financial Feasibility - The ability of a property to generate sufficient \nincome to support the use for which it was designed. Among those uses \nthat are physically possible and legally permissible, which uses will \nproduce a net return to the owner? \n• Maximally Productive - The selected use must yield the highest value \namong the possible uses. Among the feasible uses, which use will \nproduce the highest net return or the highest present worth? \n(3) An appraiser’s HBU analysis and conclusion should be documented in the \nappraisal report with a comprehensive discussion supported by relevant market \ndata or other information sources to adequately support the conclusions. \n(4) At times, an appraiser may rely in part on the analysis by another professional \nsuch as a land planner or geologist. However, an appraiser is required by \ngenerally accepted appraisal standards to exercise due diligence with respect \nto the assumptions put forth by the other professional. An appraiser must have \na reasonable basis to believe that the other professional’s work product is \ncredible and should disclose such reliance. \nG. Methodology \n(1) Treas. Reg. § 1.170A-14(h)(3)(i) and (ii) allows for two different types of \nvaluation: direct comparison or indirect analysis. \n(2) Direct comparison is to analyze sales of comparable properties to arrive at a \nconclusion as to value. A direct comparison is based on direct sales of \neasements, meaning the price paid by purchases of easements having the \nsame or similar restrictions. \n(3) Conservation easements are sold infrequently and even if the appraiser is able \nto identify sales of easements, they might not be appropriate comparables, and \nthe number of sales might not be substantial. Accordingly, most conservation \neasements are valued by indirect analysis (before and after approach). \n(4) There are three recognized valuation methodologies within the appraisal \nindustry: \n• Sales Comparison Approach (SCA) \n• Cost Approach (CA) \n• Income Capitalization Approach (ICA) \n", "66 \n \n(5) All three approaches should be considered in every appraisal assignment. This \ndoes not mean that all three approaches need to be applied. \n• Example: If the appraiser is valuing the impact of granting a conservation \nfaçade easement on a single-family home in an area in which single-family \nhomes are typically not rental income properties, then it is not necessary \nto complete the income capitalization approach. Generally, a statement \nthat due to the lack of market information the income capitalization \napproach was not completed would be sufficient. \n(6) The following brief descriptions of the three approaches (i.e., Sales, Cost and \nIncome Capitalization Approaches) were taken from The Dictionary of Real \nEstate Appraisal, Sixth Edition, which was published by The Appraisal Institute, \nChicago, Ill., 2015. \nG.1. Sales Comparison Approach \n(1) In the Sales Comparison Approach, a value indication is derived by comparing \nthe property being appraised to similar properties that have been sold recently, \napplying appropriate units of comparison, and making adjustments to the sale \nprices of the comparables based on the elements of comparison. The sales \ncomparison approach is the most common and preferred method of land \nvaluation when an adequate supply of comparable sales is available. \n(2) Elements of comparison are defined by The Appraisal of Real Estate, 14th \nEdition, The Appraisal Institute, Chicago, Ill. 2013, page 404 as “the \ncharacteristics or attributes of properties and transactions that help explain the \nvariances in the prices paid for real property.” The elements of comparison are \ndivided into two categories: transactional adjustments and property \nadjustments. \n(3) Transactional adjustments are: \n• Real property rights conveyed \n• Financing terms \n• Conditions of sale \n• Expenditures made immediately after purchase \n• Market conditions \n(4) These adjustments are “generally applied in the order listed” and are \nsuccessive. \n(5) Property adjustments are: \n• Location \n• Physical characteristics \n• Economic characteristics \n", "67 \n \n• Legal characteristics \n• Non-realty components of value. \n(6) Property adjustments are usually applied after the transactional adjustments, \nbut in no particular order and are not successive. \n(7) Layman’s terms: The appraiser compares the subject property to recently sold \nproperties. Adjustments are made to the sales to account for differences \nbetween the properties to estimate the FMV of the subject property. If there is a \nsufficient number of sales, this is the preferred valuation methodology for land. \nG.2. Cost Approach \n(1) In the cost approach, a value indication is derived for the fee simple interest in a \nproperty by estimating the current cost to construct a reproduction of (or \nreplacement for) the existing structure, including entrepreneurial incentive or \nprofit; deducting the depreciation from the total cost; and adding the estimated \nland value. Improvement cost estimates can be done with national cost \nmanuals (e.g., Marshall Valuation Service Manual), builder cost estimates or \nmarket extraction. National cost manuals only provide a cost for new \nimprovements. In utilizing these manuals, the valuation must include indirect \ncosts and an analysis for all forms of depreciation. \nG.3. Income Capitalization Approach \n(1) In the Income Capitalization Approach, an appraiser derives a value indication \nfor an income- producing property (i.e., rental property) by converting its \nanticipated benefits (cash flows and reversion) into property value. This \nconversion can be accomplished in two ways. One year’s net income \nexpectancy or an annual average of several years’ income expectancies can be \ncapitalized at a market-derived capitalization rate. Alternatively, the annual cash \nflows for the holding period and the reversion can be discounted at a specified \nyield rate. \n(2) The FMV of the subject property is estimated based on the anticipated net \nincome from the property. The appraiser estimates the potential gross income \nand subtracts vacancy and collection loss as well as operating expenses to \nestimate the net income. If one year’s net income is estimated, then that income \nis capitalized via a market-derived capitalization rate to provide an indication of \nthe FMV of the subject property. If multiple years’ net income is estimated, then \nthe cash flows and reversion are discounted at a specified yield rate to provide \na FMV indication. \nG.4. Subdivision Development Method \n(1) In the valuation of land conservation easements, many appraisals include a \nland residual analysis using a Subdivision Development Method. Although \nappraisers have referred to this approach as a different valuation methodology, \n", "68 \n \nthe Subdivision Development Method is an adaptation (or subset) of the income \ncapitalization method. The reason appraisers refer to it as “another” method is \nbecause the analysis utilizes a combination of both the sales comparison and \ncost approaches described above. \n(2) This method estimates land value assuming that subdivision and development \nof the property is the HBU of the parcel of land being appraised. When all direct \nand indirect costs, and entrepreneurial incentive (expected rate of return on \ninvestment) are deducted from the anticipated gross sales price of the finished \nlots, the resultant net sales proceeds are then discounted to present value at a \nmarket-derived rate over the development and absorption period to indicate the \nvalue of the raw land (The Dictionary of Real Estate Appraisal, Sixth Edition, \nThe Appraisal Institute Chicago, Ill., 2015, page 223). \n(3) Layman’s terms: The FMV of the subject property is estimated by first \nestimating what the “finished” lots would sell for in the marketplace. Costs, \nincluding anticipated profit, are then deducted to estimate the net income \nprojected to be generated by the property. The projected net income (i.e., cash \nflow) is discounted (for the time necessary to get approvals, finish the lots and \nsell the lots) at a specified discount rate (a/k/a yield rate) to provide a FMV \nindication. \n• Example: Parcel C is a 100-acre parcel that is zoned residential, and the \nappraiser has concluded that the HBU of the property is for a 50 lot \nresidential subdivision. An appraiser may use the sales comparison \napproach to determine the market value of the “finished” lots. The \nappraisal would provide information on similar projects in order to estimate \nthe absorption period to sell the lots. Next, the appraiser deducts the costs \nto improve the property (development costs) necessary for the subject \nproperty to attain the finished lot status. Finally, the cash flow over the \nabsorption period is discounted back to the valuation date (this accounts \nfor the time get the approvals, take the lots to the finished lot stage, and to \nsell all of the lots) to provide an estimate of the present value of the \nsubject property as raw land. \n(4) The Subdivision Development Method requires a significant amount of data \nsuch as development costs, profit margins, sales projections and the pricing of \ndeveloped lots. It is typically completed using a Discounted Cash Flow (DCF) \nanalysis. \n(5) Although the tax court has not specifically addressed the merits of utilizing the \nSubdivision Development Method, there are several decisions in the federal \ncourts that provide some insight. The Supreme Court stated in Olson v. United \nStates, 292 U.S. 246, 257 (1934) that “Elements affecting value that depend \nupon events or combinations of occurrences which, while within the realm of \npossibility, are not fairly shown to be reasonably probable, should be excluded \nfrom consideration.” \n", "69 \n \n(6) Since there are many variables involved in the Subdivision Development \nMethod, there is a greater chance of errors, which could result in an incorrect \nvaluation. Some common errors include: \n• Failure to account for time to obtain necessary project approval. \n• Failure to account for time to put infrastructure in place. \n• Failure to include the cost of the infrastructure. \n• Failure to account for time necessary to sell the units (absorption) or lack \nof support for the absorption estimate. \n• Failure to include developer’s profit. \n• Failure to account for existing competing properties as well as properties \nthat are still in the planning stage. \n• Inadequate assessment of the risk associated with the development. \nG.5. Aggregate Partnership Interest \n(1) The examiner should look at the aggregate investment by partners in the \npartnership as a factor in determining the FMV of the contributed property \nwhen, as is true in most syndicated conservation easement cases, that \npartnership’s only significant asset is the land. In other words, the amounts \ninvested by partners in acquiring their partnership interests, less any portion of \nthat investment used to pay fees and costs, may be a reasonable indicator of \nthe before value of the property held by the partnership, especially when the \npartners acquire their partnership interests shortly before the donation of the \neasement. Contemporaneous sales and transactions have been approved by \nthe courts to support a determination of value. Plateau Holdings, LLC v. \nCommissioner, T.C. Memo. 2020-93; TOT Property Holdings, LLC v. \nCommissioner, TC Docket No. 5600-17 (unpublished bench op., Nov. 22, \n2019). \nH. Transferable Development Rights \n(1) A transferable development right (TDR) is a development right held by the \nlandowner that can be transferred by the landowner for use in another location. \nA number of states, counties and cities have established TDR programs. These \nprograms are used to manage land development through the exchange of \nzoning privileges allowing property owners to separate development rights from \nthe underlying property and sell them to purchasers who want to increase the \ndensity of development in higher density areas. \n(2) For example, in New York City, an owner of a building with TDRs may be able \nto transfer (sell) unused development rights for use in other building sites \nsubject to the program restrictions. \n", "70 \n \n(3) A transfer of development rights by the landowner is not a transfer of the \nlandowner’s entire interest in the property and may not qualify for a charitable \ncontribution per IRC § 170(f)(3). Examiners and IRS appraisers should consult \nwith Counsel if the conservation easement case involves TDRs. \nX. Partnership Anti-Abuse Rules, Judicial Doctrines, and Codified \nEconomic Substance Doctrine \n(1) The following information generally relates to syndicated conservation \neasement transactions. Examiners should contact a partnership program \nanalyst or Counsel for guidance. \n(2) Judicial Doctrines and their statutory and regulatory analogs, discussed below, \nrequire extensive factual development and should not be asserted unless there \nis a sufficient basis to raise them. At the inception, when considering whether to \nassert these doctrines, the agent should consult with Counsel to consider \nwhether they are viable doctrines to be asserted. Counsel can provide support \nin developing the factual and legal arguments to be included in the RAR. \nA. Partnership Anti-Abuse Rules \n(1) If a partnership is formed or availed of in connection with a transaction a \nprincipal purpose of which is to reduce substantially the partners’ aggregate \nfederal tax liability in a manner that is inconsistent with the intent of subchapter \nK, the Commissioner can recast the transaction for federal tax purposes, as \nappropriate to achieve tax results that are consistent with the intent of \nsubchapter K, in light of the applicable statutory and regulatory provisions and \nthe pertinent facts and circumstances. See § 1.701-2(b). Whether a partnership \nwas formed or availed of with a principal purpose to reduce substantially the \npresent value of the partner’s aggregate federal tax liability in a manner \ninconsistent with the intent of subchapter K is determined based on all the facts \nand circumstances. See § 1.701-2(c) for a list of some factors. \n(2) Implicit in the intent of subchapter K are the following requirements: (1) the \npartnership must be bona fide and each partnership transaction or series of \nrelated transactions (individually or collectively, the transaction) must be \nentered into for a substantial business purpose; (2) the form of each partnership \ntransaction must be respected under substance over form principles; and (3) \nthe tax consequences to each partner and the partnership must accurately \nreflect the partners’ economic agreement and clearly reflect the partner’s \nincome, except to the extent that the results of a particular provision which \nwould otherwise not meet this requirement are clearly contemplated by that \nprovision. See § 1.701-2(a). \n(3) Section 1.701-2(b) provides that, even though the transaction may fall within the \nliteral words of a particular statutory or regulatory provision, the Commissioner \ncan determine, based on the particular facts and circumstances, that to achieve \nresults that are consistent with the intent of subchapter K: \n", "71 \n \n• The purported partnership should be disregarded in whole or in part, and \nthe partnership’s assets and activities should be considered, in whole or in \npart, to be owned and conducted, respectively, by one or more of its \npurported partners; \n• One or more of the purported partners of the partnership should not be \ntreated as a partner; \n• The methods of accounting used by the partnership or a partner should be \nadjusted to reflect clearly the partnership’s or the partner’s income; \n• The partnership’s items of income, gain, loss, deduction, or credit should \nbe reallocated; or \n• The claimed tax treatment should otherwise be adjusted or modified. \n(4) Audit Tip: Examiners should consult with Counsel if Treas. Reg. § 1.701-2 \nappears applicable to the facts of the case. CCDM 31.1.1-1 requires review by \nAssociate Chief Counsel, Pass-throughs and Special Industries (P&SI). Field \nCounsel should consult with P&SI early if this argument is potentially applicable. \n(5) Audit Tip: Examiners should look at the factors contained in Treas. Reg. § \n1.701-2(c) in determining whether partnership anti-abuse could apply to their \ncase. Some of the factors contained in the discussion of Judicial Doctrines \nbelow might also be informative. The factors contained in § 1.701-2(c) include: \n• The present value of the partner’s aggregate federal tax liability is \nsubstantially less than had the partners owned the partnership’s assets \nand conducted the partnership’s activities directly; \n• The present value of the partners’ aggregate federal tax liability is \nsubstantially less than would be the case if purportedly separate \ntransactions that are designed to achieve a particular end result are \nintegrated and treated as steps in a single transaction. For example, this \nanalysis may indicate that it was contemplated that a partner who was \nnecessary to achieve the intended tax results and whose interests in the \npartnership was liquidated or disposed of (in whole or part) would be a \npartner only temporarily in order to provide the claimed tax benefits to the \nremaining partners; \n• One or more partners who are necessary to achieve the claimed tax \nresults either have a nominal interest in the partnership, are substantially \nprotected from any risk of loss from the partnership’s activities (through \ndistribution preferences, indemnity or loss guaranty agreements, or other \narrangements), or have little or no participation in the profits from the \npartnership’s activities other than a preferred return that is in the nature of \na payment for the use of capital; \n• Substantially all the partners (measured by number or interests in the \npartnership) are related (directly or indirectly) to on another; \n", "72 \n \n• Partnership items are allocated in compliance with the literal language of \nTreas. Reg. §§ 1.704-1 and 1.704-2, but with results that are inconsistent \nwith the purpose of section 704(b) and § 1.701-2. In this regard, particular \nscrutiny will be paid to partnerships in which income or gain is specially \nallocated to one or more partners that may be legally or effectively exempt \nfrom federal income tax (because actually tax exempt or because the \ntaxpayer has unused net operating losses, capital losses, or foreign tax \ncredits); \n• The benefits and burdens of ownership of property nominally contributed \nto the partnership are in substantial part retained (directly or indirectly) by \nthe contributing partner (or a related party); \n• The benefits and burdens of ownership of partnership property are in \nsubstantial part shifted (directly or indirectly) to the distributee partner \nbefore or after the property is actually distributed to the distributee partner \n(or related party). \nB. Judicial Doctrines \nB.1. Bona Fide Partner and Partnership \n(1) Whether an entity or contractual arrangement is a partnership for federal \nincome tax purposes requires a facts-and-circumstances analysis. The \nSupreme Court in Commissioner v. Culbertson, 337 U.S. 733, 742 (1949), \nstated that there is a partnership for federal tax purposes when: \n(2) Considering all the facts – the agreement, the conduct of the parties in \nexecution of its provisions, their statements, the testimony of disinterested \npersons, the relationship of the parties, their respective abilities and capital \ncontributions, the actual control of income and the purposes for which it is used, \nand any other facts throwing light on their true intent – the parties in good faith \nand acting with a business purpose intended to join together in the present \nconduct of the enterprise. \n(3) The critical inquiry is the parties’ intent to join together in conducting business \nactivity and sharing profits. See, e.g., Commissioner v. Tower, 327 U.S. 280, \n287 (1946). See also Estate of Kahn v. Commissioner, 499 F.2d 1186, 1189 \n(2d Cir. 1974) (identifying factors a court might consider); Luna v. \nCommissioner, 42 T.C. 1067, 1077-78 (1964) (same). \n(4) In Historic Boardwalk Hall, LLC v. Commissioner, 694 F.3d 425 (3d Cir. 2012), \nthe Third Circuit applied Culbertson to determine if a partner was a bona fide \npartner. The facts in the case revealed the purported partner had neither a \nmeaningful downside risk nor a meaningful upside potential; therefore, the court \nfound that investor was not a bona fide partner. \n(5) Audit Tip: In determining whether there is a bona fide partner or partnership, \nExaminers should consider whether: \n", "73 \n \n• The property partner (i.e., the partner contributing land to the partnership) \nsought to sell the land, but instead contributed the land to the partnership \nand only remained a partner for a short period of time after the \ncontribution. \n• The property partnership conducted little to no business. \n• There is a partner who contributed cash to the property partnership for a \nnominal interest and who did not participate in the partnership or report \ngain or income from the partnership (see e.g., Andantech LLC v. \nCommissioner, 331 F.3d 972, 980 (D.C. Cir. 2003) The court found that a \nparticipants participation in a partnership “was so minimal…that his \npresence was required only to make possible the formation of a \npartnership, itself formed only to create a benefit from the method of \ntaxing that entity. In addition, there was almost no evidence that any of the \npartners had any intention of taking advantage of the potential business… \nexcept their existence.”). \n• Investors ability to transfer interests in the investment partnership are \nlimited. \n• Investment partnership has a right to buy back the investors interests on a \nspecified date based on a fair market value that is largely determined by \nthe Manager. The fair market value may or may not be subject to a cap. \nAlternatively, does the promoter have the ability to purchase back the \ninterests due to options, etc., that would result in the investors leaving the \npartnership. \n• Investors were to receive a fixed, preferred, rate of return that was \nprotected by a tax loss recapture insurance policy. The partnership \nagreement may provide that this purported rate of return be calculated \nbased on the tax benefits received from the charitable contribution \ndeduction in the partnership agreement. \n• If there were pre-existing income streams related to the property (e.g., \nlease of hunting rights) and neither the investors nor the property \npartnership reported the income properly. \n• Whether the partnership’s contribution of the easement was pre-arranged \n(i.e., the purported option to develop the property was unlikely to occur, \nunable to occur, economically or physically improbable, etc.). \n(6) Audit Tip: If a transaction contains tiers of partnerships, consideration must be \ngiven as to whether exams into the partnerships into which the investors made \ncontributions or purchased interests should also be opened in addition to the \npartnership that holds land and makes a charitable contribution. Examiners \nshould consider whether some of these factors are present at both the lower-\ntier and upper-tier partnership levels. \nB.2. Substance Over Form \n", "74 \n \n(1) Transactions that literally comply with the language of the IRC but produce \nresults other than what the IRC and regulations intend are not given effect. In \nGregory v. Helvering, 293 U.S. 465, 470 (1935), the Supreme Court found that \neven though the transaction complied with the Code, “the transaction upon its \nface lies outside the plain intent of the statute.” Therefore, the Court found that \nto give the transaction effect would be to “exalt artifice above reality and to \ndeprive the statutory provision in question of all serious purpose.” Id. In \nKnetsch v. United States, 364 U.S. 361 (1960), the Supreme Court again found \na transaction abusive, even though the transaction met every literal requirement \nof the Code. The Court stated that “there was nothing of substance to be \nrealized by Knetsch from this transaction beyond a tax deduction.” Id. at 366. \nSee also Allen v. Commissioner, 92 T.C. 1, 8, 11 (1989) (explaining that “the \ntransaction in its entirety must be examined in a realistic economic sense to \ndetermine the tax consequences” and that transactions where tax savings are \nmore than twice the cash investment are subject to scrutiny). \n(2) Audit Tip: In determining whether the substance over form doctrine applies, \nExaminers should consider whether: \n• The property partner (i.e., the partner contributing land to the partnership) \nsought to sell the land. \n• The property partner, shortly after the contribution of the land to the \nproperty partnership, sold its entire interest (or substantial portion of its \ninterest) to investment partnership (see e.g., Margolis v. Commissioner, \n337 F.2d 1001 (9th Cir. 1964) (Taxpayer transferred land into a dormant \ncorporation and twenty days later sold all the stock in the corporation and \nreported his gain on the transaction as long-term capital gain from the sale \nof stock. The Ninth Circuit ruled that it was in fact a sale of land with \ntaxpayer’s interest held for sale in the ordinary course of his business.). If \nthe property partner retains an interest in the partnership, additional facts \nmust be considered (e.g., whether the partner held him/herself out to be a \npartner, whether the partner reported any income from the land, whether \nthe partner received a Schedule K-1, etc.). Examiners should consult with \nCounsel in these types of cases. \n• The investment partnership’s intent was really to purchase the land (e.g., \npromotion materials predate the purchase of the interest in the property \npartnership interest and/or the investment partnership was already in \ndiscussion with a charitable organization at or before the purchase of the \nproperty partnership interest). \n• Whether the partnership’s contribution of the easement was pre-arranged \n(i.e., the purported option to develop the property was unlikely to occur, \nunable to occur, economically or physically improbable, etc.). \nB.3. Step Transaction Doctrine \n", "75 \n \n(1) Under the step transaction doctrine, a series of formally separate steps may be \ncollapsed and treated as a single transaction if the steps are in substance \ninterrelated and focused toward a particular result. Courts have applied three \nalternative tests in deciding whether the step transaction doctrine should be \ninvoked in a particular situation: the binding commitment test, the end result \ntest, and the interdependence test. \n(2) The binding commitment test is the most limited and rigorous of the three tests. \nIt looks to whether, at the time the first step was entered into, there was a \nbinding commitment to undertake the later transactions. Commissioner v. \nGordon, 391 U.S. 83, 96 (1968). \n(3) The end result test analyzes whether the formally separate steps merely \nconstitute prearranged parts of a single transaction intended from the outset to \nreach a specific end result. This test relies on the parties’ intent at the time the \ntransaction is structured. The intent the courts focus on is not whether the \ntaxpayers intended to avoid taxes, but whether the parties intended from the \noutset “to reach a particular result by structuring a series of transactions in a \ncertain way.” True v. United States, 190 F.3d 1165, 1175 (10th Cir. 1999). \n(4) Finally, the interdependence test looks to whether the steps are so \ninterdependent that the legal relations created by one step would have been \nfruitless without a completion of the later series of steps. See Penrod v. \nCommissioner, 88 T.C. 1415, 1430 (1987). Steps are generally accorded \nindependent significance if, standing alone, they were undertaken for valid and \nindependent economic or business reasons. Security Indus. Ins. Co. v. United \nStates, 702 F.2d 1234, 1246 -1247 (5th Cir. 1983). See also Greene v. United \nStates, 13 F.3d 577, 584 (2d Cir. 1994). \n(5) The existence of economic substance or a valid non-tax business purpose in a \ngiven transaction does not preclude the application of the step transaction \ndoctrine. Events such as the actual payment of money, legal transfer of \nproperty, adjustment of company books, and execution of a contract all produce \neconomic effects and accompany almost any business dealing. Thus, the \ncourts do not rely on the occurrence of these events alone to determine \nwhether the step transaction doctrine applies. “Likewise, a taxpayer may \nproffer some non-tax business purpose for engaging in a series of transactional \nsteps to accomplish a result he could have achieved by more direct means, but \nthat business purpose by itself does not preclude application of the step \ntransaction doctrine.” True v. United States, 190 F.3d at 1177. See also \nAssociated Wholesale Grocers v. United States, 927 F.2d 1517, 1527 (10th Cir. \n1991); Long Term Capital Holdings, et al. v. United States, 330 F. Supp. 2d \n122, 193 (D. Conn. 2004), aff’d without published opinion 150 Fed. Appx. 40 \n(2d Cir. 2005). \n(6) Audit Tip: In determining whether the step transaction doctrine applies, \nExaminers should consider whether: \n", "76 \n \n• The property partner (i.e., the partner contributing land to the partnership) \nhad no business purpose for contributing the land to a partnership. \n• The property partner sought to sell the land. \n• The property partner, shortly after the contribution of the land to the \nproperty partnership, sold its entire interest (or substantial portion of its \ninterest) to investment partnership. If the property partner retains an \ninterest in the partnership, additional facts must be considered (e.g., \nwhether the partner held him/herself out to be a partner, whether the \npartner reported any income from the land, whether the partner received a \nSchedule K-1, etc.) Examiners should consult with Counsel in these types \nof cases. \n• The investment partnership was already in discussion with a charitable \norganization at or before the purchase of the property partnership interest. \n• Whether the partnership’s contribution of the easement was pre-arranged \n(i.e., the purported option to develop the property was unlikely to occur, \nunable to occur, economically or physically improbable, etc.). \nC. Codified Economic Substance Doctrine \n(1) Section 7701(o)(1) provides that, in the case of any transaction to which the \neconomic substance doctrine is relevant, such transaction shall be treated as \nhaving economic substance only if (A) the transaction changes in a meaningful \nway (apart from federal income tax effects) the taxpayer’s economic position, \nand (B) the taxpayer has a substantial purpose (apart from federal income tax \neffects) for entering into such transaction. \n(2) In cases where a taxpayer relies on profit potential, the potential for profit of a \ntransaction shall be taken into account in determining whether the requirements \nof IRC § 7701(o)(1)(A) and (B) are met with respect to the transaction only if the \npresent value of the reasonably expected pre-tax profit from the transaction is \nsubstantial in relation to the present value of the expected net tax benefits that \nwould be allowed if the transaction were respected. Fees and other transaction \nexpenses shall be taken into account as expenses in determining pre-tax profit. \nIRC § 7701(o)(2)(A) and (B). \n(3) For additional information about the codified economic substance doctrine, see \nNotice 2010-62; Notice 2014-58. Examiners considering application of the \ncodified economic substance doctrine are encouraged to coordinate with \nCounsel. \n(4) Audit Tip: Examiners should consult with local Counsel if the codified \neconomic substance doctrine appears applicable to the facts of the case. \nCCDM 31.1.1-1 requires review by an Associate Chief Counsel in novel cases \n(i.e., when the doctrine has not previously been applied to that type of \ntransaction). See Chief Counsel Notice 2012-008 and Chief Counsel Notice \n", "77 \n \n2016-009. See also IRM 4.8.9.9.2.1(1)(p). LB&I Examiners must also secure \napprovals required in IRM Exhibit 4.46.4-4. \n(5) Audit Tip: Examiners should also be alert to other appropriate arguments and \nconsult with Counsel as necessary. \n(6) Audit Tip: In determining whether a transaction has economic substance, \nExaminers should consider: \n• Whether the transaction is promoted, pre-packaged (e.g., a promoter \nprovides potential clients with promotional materials, regularly markets the \nproduct, and facilitates the transaction year to year). This could also \ninclude the use of almost identical, template documents used to effectuate \nthe transaction. \n• Whether the transaction includes unnecessary steps (e.g., contribution of \nthe land to the property partnership by the property partner when the facts \ndemonstrate that the property partner’s goal was to sell the land). \n• Transaction has no meaningful potential for profit apart from tax benefits \n(e.g., property partnership did not engage in any business). \n• Investment partnership has a right to buy back the investors interests on a \nspecified date based on a fair market value that is largely determined by \nthe Manager. The fair market value may or may not be subject to a cap. \nAlternatively, does the promoter have the ability to purchase back the \ninterests due to options, etc., that would result in the investors leaving the \npartnership. \n• Transaction has no significant risk of loss (e.g., presence of certain audit \ninsurance that also covers original contribution). \n• Transaction is outside the investor’s ordinary business operations. \n• Whether the partnership’s contribution of the easement was pre-arranged \n(i.e., the purported option to develop the property was unlikely to occur, \nunable to occur, economically or physically improbable, etc.). \nXI. Preplanning the Examination \nA. Overview \n(1) IRM 4.10.2, Pre-contact Responsibilities, requires Examiners to perform a pre-\ncontact analysis, including a review of the income tax return, any attachments \nto the return, and internal and external sources of information. \nB. Review of Return \n(1) Only itemizers may claim a charitable contribution deduction. A conservation \neasement deduction is reported on Schedule A, Itemized Deductions (PDF), \nLine 12, “Other than by cash or check.” Any carryover of charitable \ncontributions originating from earlier tax years appears on the “Carryover from \nPrior Year,” Line 13. \n", "78 \n \n(2) Audit Tip: Examiners should determine, at the beginning of the examination, \nthe tax year of the contribution. If the amount claimed on the return is a \ncarryover from an earlier tax year, the original return, including all attachments, \nmust be secured. This is important 1) to verify compliance with substantiation \nrequirements, and 2) to ensure that all open tax years are included in the \nexamination. \nB.1. Form 8283 – Appraisal Summary \n(1) Form 8283, Noncash Charitable Contributions (PDF), referred to in DEFRA § \n155 and Treas. Reg. § 1.170A-13(c)(4) as the “appraisal summary,” is the \nstarting point to gather information about the conservation easement deduction. \n(2) Form 8283 must be completed and attached to the return for all noncash \ncharitable contribution deductions greater than $500. IRC § 170(f)(11)(B). For \nnoncash charitable contribution deductions in excess of $5,000, the taxpayer \nmust complete Section B of the Form 8283. Treas. Reg. § 1.170A-13(c)(2); \nTreas. Reg. § 1.170A-16(d)(1)(iii). For contributions after July 30, 2018, these \nrules also apply to carryover years. Treas. Reg. § 1.170A-16(f)(3). \n(3) If the donation originates from a flow-through entity (such as S corporation or \npartnership), the partner or shareholder must include a copy of the entity’s Form \n8283 with the return on which the deduction is first claimed. Treas. Reg. § \n1.170A-13(c)(4)(iv)(G); Treas. Reg. § 1.170A-16(f)(4). \n(4) Close inspection of Form 8283 may indicate an improper deduction or \novervalued conservation easement. Look for: \n• Incomplete or missing information, such as an inadequate description of \nthe property or missing acquisition date or basis in the property. \n• Missing appraiser or donee signatures. \n• Inconsistent dates when compared to the appraisal or other documents. \n• A short time period between the acquisition of the property and the \ndonation date. \n• High valuation of the easement as compared to the basis of the underlying \nproperty, in light of holding period and the market conditions for the \nrelevant market. \n• High valuation of the easement in light of the total value of the land. \n• Use of an appraiser who does not generally perform appraisals where the \neasement is located. \n(5) Audit Tip: Completion of the appraisal summary (Form 8283) does not satisfy \nthe CWA requirement in IRC § 170(f)(8) and Treas. Reg. § 1.170A-13(f). A \nCWA is required for any contribution of $250 or more. Failure to comply with the \nCWA requirement will result in disallowance of the charitable contribution \n", "79 \n \ndeduction. See Chapter 2 for a discussion of what information must be included \nin the CWA and when it must be obtained by the taxpayer. \nB.2. Signature Requirements \n(1) Form 8283, Section B, Part II, Taxpayer (Donor) Statement, is not relevant \nunless the appraised value for an item is $500 or less. It is typically left blank for \nconservation easement donations. \n(2) Form 8283, Section B, Part III, Declaration of Appraiser, must be signed and \ndated by the qualified appraiser for donations in excess of $5,000. Treas. Reg. \n§ 1.170A-13(c)(4)(i)(C); Treas. Reg. § 170A-16(d)(1)(iii). \n(3) Form 8283, Section B, Part IV, Donee Acknowledgment, must be signed by an \nofficial authorized to sign the tax returns of the donee organization or a person \nspecifically designated to sign Form 8283. Treas. Reg. § 1.170A-13(c)(4)(i)(B); \nTreas. Reg. § 170A-16(d)(5). Examiners should look for incomplete or \nimproperly completed donee acknowledgments and determine if there are any \ndiscrepancies with other available information. \nB.3. Return Attachments \n(1) A qualified appraisal, prepared and signed by a qualified appraiser, is required \nto be attached to the return if the deduction claimed (1) exceeds $500,000, or \n(2) regardless of the dollar amount claimed, if the deduction relates to a \ncontribution of a façade easement on a building or structure in a registered \nhistoric district. IRC §§ 170(f)(11)(D) and 170(h)(4)(B)(iii)(I). \n(2) Note: The special rule for façade easements does not apply to properties listed \non the National Register. \n(3) See Chapter 7 for guidance on qualified appraisals. \n(4) If a qualified appraisal was required to be attached, but was not attached to the \noriginal return claiming the conservation easement, the charitable contribution \ndeduction will be disallowed for failing to meet the IRC § 170(f)(11) \nrequirements. Section 170(f)(11)(A)(ii)(II), however, provides for a limited \nexception to this rule. The charitable contribution deduction may still be allowed \nif it is shown that the failure to meet such requirements is due to reasonable \ncause and not willful neglect. \n(5) If the Examiner does not have the original return or has been assigned a \ncarryover tax year, the original return must be ordered from the Service Center \nusing SC 45 to verify compliance with the requirement to attach a qualified \nappraisal. \n(6) If a return is filed electronically, any attachments, including the appraisal, must \nbe filed with the return. The attachments can be scanned and attached \nelectronically to the e-file return as a PDF file. If documents are not submitted \nelectronically, they must be mailed with the Form 8453, U.S. Individual Income \n", "80 \n \nTax Transmittal (PDF) for an IRS e-file Return. The Examiner will need to \nrequest the original Form 8453 with attachments to determine if the taxpayer \nhas met the substantiation requirements. \n(7) IDRS command code TRDBV will show whether the Form 8453 was filed and \nthe related Document Locator Number (DLN). The Form 8453 and any \nattachments can be secured using command code ESTAB with the identified \nDLN. If the TRDBV does not show the filing of a Form 8453, the IDRS print \nshould be included in the examiner’s work papers to demonstrate that there is \nno record of filing the required return attachments. \n(8) In some cases, taxpayers attach baseline studies, correspondence or other \ndocuments related to the easement donation. This information should be \nreviewed for unusual items or inconsistencies and ultimately compared to actual \nsource documents. \nB.4. Other Tax Issues \n(1) The Examiner is responsible for determining the scope of the audit and should \nbe alert to other potential tax issues on the tax return, which may or may not be \nrelated to the conservation easement deduction. \n(2) Some examples of potential issues related to the conservation easement \ndonation are cash donations to the easement donee, income generated from \nthe sale of state tax credits and recapture of rehabilitation tax credits. \n(3) IRM 4.10.4.3, Minimum Requirements for Examination of Income, requires \nExaminers to consider gross income during the examination of all income tax \nreturns regardless of the type of return filed by the taxpayer. All deviations from \nminimum probes need to be documented and approved by the group manager. \nB.5. TEFRA Considerations \n(1) An individual’s income tax return may be selected for examination based on a \nlarge noncash contribution or carryover. Examiners must determine as quickly \nas possible whether the donation originated from a partnership or limited liability \ncompany (LLC) treated as a partnership for federal income tax purposes. This \ninformation may not be readily available by inspection of the return particularly \nfor carryovers. \n(2) The determination of the tax treatment of partnership items is made at the \npartnership level. If the easement donation was made by a partnership or LLC \ntreated as a partnership, which is subject to TEFRA, the charitable contribution \nis a partnership item. An adjustment to the charitable contribution deduction \ncannot be proposed without conducting an examination of the originating donor \nentity (i.e., Form 1065 entity). If the entity is a TEFRA entity, the unified audit \nprocedures for partnership proceedings must be followed. These procedures \nmay present additional administrative complexities due to statute concerns, \n", "81 \n \ninvolvement of multiple tiers of ownership, and the location of the key case \nentity and partnership investors. \n(3) It is possible that the minimum assessment period for partnership items per IRC \n§ 6229 may have expired. While the government can best protect its interest by \nextending the IRC § 6229 period of assessment before it expires and \nconducting a partnership proceeding that includes all the partners, the \ngovernment is not precluded from conducting a partnership proceeding if the \nIRC § 6501 assessment period for any of the partners is still open. \n(4) Examiners should consult with their local Technical Services Passthrough \nCoordinator for guidance on TEFRA examinations. A list of current coordinators \ncan be found on the IRS Virtual Library. \n(5) TEFRA was repealed for tax years beginning on or after January 1, 2018. \nB.6. BBA Considerations (Taxable Years Beginning on or After \nJanuary 1, 2018) \n(1) The Bipartisan Budget Act replaced the auditing procedures for partnerships \nunder TEFRA with the centralized partnership audit regime, referred to as BBA. \nPartnerships that file returns for tax years starting January 2018 must follow \nrules under the BBA. Refer to the BBA resources on the IRS Virtual Library and \nconsult with the Technical Services Passthrough Coordinator. \nC. Internal Sources of Information \n(1) Information available from internal sources may be useful in preplanning for the \nexamination, including the Conservation Easement issue Web page on the IRS \nVirtual Library, IDRS and contacts with program analysts and the Office of \nProfessional Responsibility. \nC.1. IRS Intranet \n(1) Training materials, job aids, recent court decisions and other reference \nmaterials on conservation easements can be found on IRS Virtual Library, Form \n1040 Knowledge Base. Examiners should refer to the Virtual Library page for \nupdated information. \nC.2. Program Analysts \n(1) Examiners are encouraged to contact program analysts (PAs) assigned to this \nissue to discuss case development as early as possible in the examination. \nContact information can be found on the Virtual Library page. PAs can explain \nthe statutory requirements, help the examiner analyze the documents, and write \nreports. \nC.3. Integrated Data Retrieval System – IDRS \n", "82 \n \n(1) Examiners should review all available IDRS information to identify any \nadditional donations and carryovers. A review of the taxpayer's filing history \nover several years can provide insight. \n(2) Reviewing the taxpayer's Information Returns Processing (IRP) documents and \nsecuring a yK1 link analysis may reveal related flow-through entities associated \nwith the easement contribution. \nC.4. Façade Filing Fee Verification \n(1) Donors must pay a $500 filing fee to the U.S. Treasury for donations of \neasements on buildings in registered historic districts if they claim a deduction \nof more than $10,000. IRC § 170(f)(13)(A)-(B). The fee is to be used to enforce \nthe provisions of IRC § 170(h). IRC § 170(f)(13)(C). \n(2) No deduction is allowed for façade easement deductions over $10,000 unless \nthe taxpayer includes the fee with the return. IRC § 170(f)(13)(A). Payment is \ntransmitted to the IRS using Form 8283-V, Payment Voucher for Filing Fee \nunder Section 170(f)(13) (PDF). \n(3) IDRS reports IMFOLT (individual returns) and BMFOLT (corporate/partnership \nreturns) will show a TC (Transaction Code) 971 with AC (Action Code) 670 to \nidentify the payment of the filing fee. Examiners can also contact a program \nanalyst for confirmation of fee payment. \nC.5. Tax Exempt Organization Search \n(1) Tax Exempt Organization Search (previously Publication 78) should be \nconsulted to verify whether the organization has tax-exempt status. The online \nsearchable version can be found IRS.gov. Click on “Charities and Nonprofits,” \nthen “Search for Charities” to search for qualified organizations by name and \ncity. \n(2) Examiners should be aware that a listing on the Tax Exempt Organization \nSearch is not always necessary in order to qualify to receive tax deductible \ncontributions. \n(3) Some entities eligible to receive tax-deductible charitable contributions may not \nbe listed in Tax Exempt Organization Search, such as churches and certain \naffiliated organizations, group exemption subordinate organizations, and \ngovernmental units (including Indian tribal governments). \n(4) Only qualified organizations that meet the requirements of IRC § 170(h)(3) and \nTreas. Reg. § 1.170A-14(c)(1) are eligible to receive a deductible conservation \neasement contribution. The donee organization must have the commitment to \nprotect the conservation purpose and have the resources to enforce the \nconservation restrictions. \n(5) See Chapter 4 for detailed discussion on qualified organization requirements. \nC.6. Office of Professional Responsibility \n", "83 \n \n(1) Examiners can search the Office of Professional Responsibility intranet Web \npage for any previous disciplinary actions against the appraiser or the return \npreparer. The presence of prior sanctions suggests a need for extra scrutiny by \nthe examiner. \nD. External Sources of Information \n(1) Examination of a charitable contribution deduction for a conservation easement \nis fact intensive, requiring examiners to gather and analyze information to \ndetermine whether the charitable contribution deduction is allowable. Review of \ndocuments from external sources such as the Internet, public records, and the \nNational Park Service in advance of taxpayer contact can help streamline the \nexamination process. \nD.1. Internet Research \n(1) The Internet (using Google or other similar search engine) can be an excellent \nsource of background information relevant to the taxpayer, donee organization, \nand appraiser. \nD.2. Taxpayer \n(1) Examiners should search the Internet for information on the taxpayer's \nbusiness, personal history, reputation in the community, and involvement with \nconservation issues and organizations. \n(2) A particular easement donation may have received local newspaper coverage \nat the time of the donation. News articles may provide evidence regarding \ncharitable intent, quid pro quo, transactions between related parties, the donor's \nbasis, or whether the property constitutes inventory in the hands of the \ntaxpayer. \nD.3. Donee Organization \n(1) The Tax Exempt Organization Search on IRS.gov and Guidestar.org provide \ntax returns of charitable organizations and other important information relating \nto the organizations. Examiners will need to register online to access the \nGuidestar information. Returns provided on Guidestar, however, generally do \nnot include schedules of contributors. The Economic Research Institute also \ncan be used to research charitable organizations. \n(2) An Internet search of the donee organization may provide relevant information \non the organization. Most organizations have their own websites, which provide \na wealth of information, especially regarding their charitable purpose and goals. \nThis research may reveal relationships between the donor and donee \norganization. Transactions between related parties by either position or \nbusiness activity must be scrutinized closely. \n", "84 \n \n(3) Audit Tip: A \"self-serving\" donee organization organized solely for the purpose \nof accepting one easement may lack charitable purpose or be engaged in self-\ndealing. If there is a question or concern as to the operations of the \norganization, examiners should submit a referral to Tax Exempt and \nGovernmental Entities (TEGE) through the Specialist Referral System (SRS). \nD.4. Appraiser \n(1) Examiners can obtain information about the appraiser and appraisal firm, such \nas their professional credentials, expertise with respect to conservation \neasements, and past business dealings with the donor or donee organization. \nThis information is helpful in determining if the appraiser is a \"qualified \nappraiser\" and may provide some insight into any business history with the \ntaxpayer or donee organization. \n(2) License information regarding jurisdictions, history and disciplinary actions can \nbe found on The Appraisal Subcommittee of the Federal Financial Institutions \nExamination Council webpage. You can search for information on a specific \nappraiser by selecting the “find an appraiser” button or utilize this link: Find an \nAppraiser. Some states also provide appraisal licensing information online. \nExaminers or IRS appraisers can contact the various state boards by telephone \nto determine if there are any past or pending disciplinary actions against the \nappraiser. The contact information for each state’s appraiser regulatory \nprogram can be found on the Appraisal Subcommittee Web page at this link: \nState Appraisal Regulatory Information Web page. \n(3) Audit Tip: An appraisal summary or a qualified appraisal must include the \nname, address, and identifying number of the qualified appraiser that signs the \nappraisal summary or qualified appraisal. Treas. Reg. §§ 1.170A-13(c)(4)(ii)(I); \n1.170A-13(c)(3)(ii)(E); 1.170A-16(d)(3)(iii) and 1.170A-17(a)(3)(iv)(A). For a \nqualified appraisal, the appraiser's professional qualifications must be included. \nInformation found on the Internet should be used to verify the accuracy of the \ninformation provided with the return. \nD.5. Public Records \n(1) Examiners must secure, directly from the appropriate recordation office, the \nconservation easement deed, any subordination agreements, and other \npertinent documents that are recorded with the deed. If online research is not \navailable, the Examiner or the IRS appraiser may need to travel to the \nrecordation office to obtain this information. Use of research services such as \nAccurint alone is not sufficient. \n(2) Audit Tip: Until the easement is recorded, the easement is not enforceable in \nperpetuity. Treas. Reg. § 1.170A-14(g)(1). In some cases, taxpayers claim the \ndonation in the wrong tax year. See Chapter 2 for a detailed discussion on \nstatutory requirements. \n", "85 \n \n(3) Examiners should determine if there were any preexisting restrictions on the \nproperty imposed by local or state ordinances, zoning, or the rules of the \nhistoric districts. There will be no loss in value as a result of the granting of the \neasement if the easement does not impose new restrictions on the property. \nIRS appraisers have significant experience with this type of research and will \ngenerally address this as part of their fieldwork. \n(4) In addition to obtaining copies of the recorded instruments, examiners should \nresearch the property's ownership, sales, and mortgage history. Be alert to \nrecent sales or mortgages on the property that may provide insight into the \neasement value. Insurance records may also be informative. \n(5) The IRS appraiser will need to identify the property owner of the encumbered \nproperty. Identify any contiguous properties, and any other properties owned by \nthe taxpayer or a related party, in order to properly apply the \ncontiguous/enhancement rules in valuing the property and determining the \nproper amount of the deduction. Examiners should verify ownership on the date \nof the contribution through interviews and review of public records (in the county \nwhere the property is located). \n(6) Many conservation easements originate from flow-through entities (i.e., S \ncorporations and partnerships). The allocation of contributions to the \nshareholders or partners is reported on Schedule K-1, Partners Share of \nIncome, Deductions, Credits, etc. Examiners should verify the percentage of \nownership and determine if the contribution amount was properly allocated. \nD.6. National Park Service \n(1) For donations of easements on certified historic structures, examiners must \nverify that the property is a certified historic structure and that the status was \nobtained either at the time the transfer was made or at the due date (including \nextensions) for filing the donor’s return for the taxable year in which the \ncontribution was made. IRC § 170(h)(4)(C) and Treas. Reg. § 1.170A-\n14(d)(5)(iii). The taxpayer will generally provide this information in response to \nthe initial information document request (IDR). \n(2) If a building is individually listed on The National Register of Historic Places, no \ncertification is required from the NPS Historic Preservation Division. If a building \nis located in a registered historic district, it must be certified by the Secretary of \nthe Interior to the Secretary of Treasury as being of historic significance to the \ndistrict. Treas. Reg. § 1.170A-14(d)(5)(iii)(B). \n(3) Review the returns for the relevant period to see if the Rehabilitation Tax Credit \nwas claimed. If the credit was claimed, consult the program analysts, Counsel, \nand the IRS Virtual Library. \n(4) Audit Tip: To obtain certification from NPS, the taxpayer would have submitted \nForm 10-168 (PDF) to the Historic Preservation Division for certification that the \n", "86 \n \nbuilding contributes to the district. Examiners should obtain a copy of the \ncertification and any related documents from the taxpayer or NPS. \nE. Interviews \n(1) As in all income tax examinations, the interview is an important component of a \nquality examination. The interview is a crucial step in securing the necessary \nbackground information to evaluate the claimed deduction. See IRM 4.10.3.3, \nInterviews: Authority and Purpose. \n(2) The best time for interviewing the taxpayer is usually after conducting the \nresearch discussed above, reviewing the easement documents and assignment \nof an IRS appraiser to the case (if applicable). If possible, the Examiner and \nIRS appraiser should jointly interview the taxpayer. \n(3) Examiners will usually need to interview the taxpayer. The representative \ncannot substitute for the taxpayer. Do not provide written questions to the \nrepresentative to ask the taxpayer. In some instances, it may be necessary to \nsummons the taxpayer. \n(4) Audit Tip: Develop a timeline of events surrounding the donation and a \ndiagram depicting the transaction. \nF. Information Document Requests \n(1) A sample Information Document Request (IDR) can be found on the IRS Virtual \nLibrary. The IDR should be modified to meet the specific needs of the \nexamination, requesting only relevant information. Documents from the \ntaxpayer are necessary not only to verify the easement donation, but also to \ncollect initial documentation of the FMV of the easement. See Chapter 2 for a \ndetailed discussion of what documents are required to substantiate a \nconservation easement contribution. \n(2) Securing documents is only the beginning of the examination of a conservation \neasement deduction. A final determination cannot be made without careful \nreview of the documents and background information, coordination with LB&I \nEngineering on the valuation (as appropriate), and in many cases, third party \ncontacts. \nG. Valuation Expert Involvement \n(1) Valuation of the conservation easement is an important part of a conservation \neasement deduction examination. A referral to LB&I Engineering for an IRS \nappraiser or an outside expert will generally be required. Examiners and the \nIRS appraiser need to work together to avoid duplication of effort, share \ninformation, and rely on each person's specific job skills to fully develop the \ncase. \n", "87 \n \n(2) Note: The Examiner has primary responsibility for the non-valuation aspects of \nthe issue and must not suspend or delay work on the income tax case pending \nreceipt of LB&I Engineering’s valuation report. \nG.1. Referral to LB&I Engineering \n(1) A referral is made through the Specialist Referral System (SRS). Referrals to \nLB&I Engineering should be considered in all conservation easement cases. \nThe referral must be made early in the examination process to allow sufficient \ntime for LB&I Engineering input. The Examiner should inform the taxpayers and \ntheir Representative of an IRS appraiser’s participation and expected \nexamination timeframes. \n(2) Examiners should promptly provide the IRS appraiser with: \n• A copy of the return or pertinent part of the return \n• Form 8283, including attachments \n• A copy of the appraisal (if attached or once received) \n• Other pertinent information attached to the return \n• A recorded copy of easement deed including any attachments and \ncorrespondence \n• Baseline study of the property (if attached or once received) \n• Contemporaneous Written Acknowledgment (IRC § 170(f)(8)) \nG.2. Referral Outcomes \n(1) LB&I Engineering may accept or decline the referral, depending on the \ndeduction amount, available staffing resources, and other factors. In lieu of an \n“appraisal review,” the IRS appraiser may provide informal feedback to the \nExaminer as to the reasonableness and adequacy of the taxpayer’s appraisal. \n(2) If the formal referral is accepted, a meeting should be scheduled with the \nassigned IRS appraiser to discuss duties and timeframes for completion. This \nmeeting should be documented in memo form. The IRS appraiser and \nExaminer should coordinate their actions throughout the examination. \n(3) Generally, the scope of the IRS appraiser’s work is limited to valuation and \nqualified appraisal issues, and the Examiner will handle the legal issues under \nIRC § 170. However, there is some overlap of responsibilities. For example, the \ninspection of the property and interview of the taxpayer are important for both \nthe IRS appraiser and the Examiner and should (to the extent possible) be \nconducted jointly. \n(4) If funds are available, LB&I Engineering may hire an outside fee appraiser. \n(5) Examiners can seek assistance from program analysts to discuss alternatives \nand assistance in resolution of any issues with LB&I Engineering. \n", "88 \n \nG.3. LB&I Engineering Products \n(1) The IRS appraiser will generally prepare an “appraisal review with an opinion of \nvalue,” which is a detailed review of the taxpayer’s appraisal and includes an \nestimate of the FMV of the conservation easement. In other cases, the IRS \nappraiser will prepare an appraisal. \n(2) In some cases, the IRS appraiser may provide an “appraisal review,” which is \nsimply a critique of completeness and reliability of the taxpayer’s appraisal \nwithout determining the FMV of the conservation easement. Another option is \nan informal consultation, where the IRS appraiser gives informal feedback on \nthe taxpayer’s appraisal. \nG.4. Outside Experts \n(1) The IRS hires outside valuation experts (“outside fee appraisers”) if funds are \navailable. Requests for use of an outside fee appraiser are made using the SRS \nreferral process. \n(2) An outside fee appraiser must be approved through the IRS procurement \nprocess. LB&I Engineering is responsible for working with the Contracting \nOfficer’s Representative (COR) to identify experts, solicit bids, arrange for \nbackground investigations, and execute the contract. \n(3) The outside fee appraiser reports only address valuation of the conservation \neasement. Examiners will need to address the legal issues under IRC § 170. \nH. Consultation with Counsel \n(1) Because examination of a conservation easement deduction involves review of \na number of legal documents, Examiners will need to consult with Counsel. \n(2) Counsel should be engaged early in the examination to assist with review of the \nlegal documents for areas of IRC § 170 noncompliance, such as conservation \npurpose, inconsistent use of the property, perpetuity, subordination and \nallocation of proceeds. It is imperative that examiners consult with Counsel in \nthe case of raising any of the following: bona fide partner or partnership, \npartnership anti-abuse rules under Treas. Reg. § 1.701-2, judicial doctrines \n(e.g., substance over form or step transaction doctrine) or the codified \neconomic substance doctrine under IRC § 7701(o). See Chapter 10 for \nadditional information. Examiners will need to be alert to court decisions that \ncould affect their examination. Recently decided cases relevant to the \nconservation easement issue can be found on the IRS Virtual Library. \n(3) Audit Tip: Certain arguments, including those made under Treas. Reg. § \n1.701-2 and the codified economic substance doctrine, require Associate Office \nreview. CCDM 31.1.1-1. \nI. Coordination with TEGE \n", "89 \n \n(1) The Examiner should determine whether the donee organization is or has been \nunder examination by TEGE. If so, the Examiner should contact the Exempt \nOrganization (EO) Examiner assigned to the case to obtain pertinent \ninformation and to coordinate examination activities, as appropriate. \n(2) The EO Examiner can assist in securing records from the donee organization \nand provide detailed information on the organization. Coordination with TEGE \navoids duplication of effort and unnecessary contacts with the donee \norganization. \n(3) During the examination, the Examiner may need to consider a referral to TEGE \nfor examination of the donee organization. Some factors that may warrant a \nreferral include: \n• False or misleading statements by the donee organization regarding the \ntax requirements or valuation of contributions of conservation easements. \n• Evidence of undue influence on the taxpayer’s appraiser by the donee \norganization. \n• Presence of related party transactions between the donor and the donee \norganization. \n• Lack of any charitable activity by the donee organization, or activities \ncontrary to its stated charitable purpose. \n• Use of a related \"for-profit\" business to process easement donations. \n• Information indicating that the donor’s conservation contribution lacked a \n“conservation purpose” for purposes of IRC § 170(h) could also have a \nbearing on the donee organization’s exempt status, particularly if it has \naccepted other conservation contributions that lack a conservation \npurpose. \n(4) Examiners can make referrals to TEGE using the SRS referral process or \nsubmit a request for consultation. \nXII. \n Conducting the Examination \nA. Overview \n(1) Conservation easement examinations are very challenging cases requiring \nsubstantial factual development and review of legal documents. A team \napproach (examiner working with LB&I Engineering, Counsel, and program \nanalysts) is the most effective way to conduct these examinations. \n(2) Examiners will need to look beyond information provided on the tax return and \nanalyze the substance of the transaction rather than the mere form of the \ntransaction. Examiners must employ investigative skills to identify any \nomissions or discrepancies of material facts. \n(3) During an examination, the examiner will obtain documentation, conduct \ninterviews of the taxpayer and third parties, and perhaps visit the property \n", "90 \n \nencumbered by the easement. The examiner must evaluate all of this \ninformation to determine if the taxpayer meets the: \n• General statutory requirements for all charitable contributions per IRC § \n170. \n• Specific statutory requirements for qualified conservation contributions per \nIRC § 170(h) and Treas. Reg. § 1.170A-14, including compliance with one \nor more of the conservation purposes listed in IRC § 170(h)(4)(A). \n• Contemporaneous written acknowledgment requirement under IRC § \n170(f)(8). \n• Substantiation requirements and, specifically, the qualified appraisal and \nappraiser requirements in IRC § 170(f)(11), Notice 2006-96, and Treas. \nReg. § 1.170A-13. The substantiation requirements of Treas. Reg. § \n1.170A-16 are applicable to contributions made after July 30, 2018. \n• Statutory (DEFRA) and regulatory requirements for Form 8283. Treas. \nReg. § 1.170A- 13(c)(4). \n• Baseline requirements. Treas. Reg. § 1.170A-14(g)(5). \nB. Interviews \n(1) As with all examinations, interviewing the taxpayer who donated the \nconservation easement is an important step in the development of facts. The \ninterview provides important information regarding the history of the property \nand the taxpayer’s: \n• Intent in making the easement donation. \n• Understanding of the transaction. \n• Efforts to comply with the statutory and regulatory requirements. \n• Due diligence in obtaining a correct appraisal. \n(2) If possible, the examiner and IRS appraiser should conduct a joint interview. \nReview of the conservation easement deed, baseline study and the taxpayer’s \nappraisal, prior to the interview, will help the Examiner and IRS appraiser carry \nout a focused interview. In some cases, more than one interview may be \nrequired to gather all relevant facts. \n(3) Audit Tip: Some representatives may request that questions be submitted in \nwriting prior to the interview or in lieu of an interview. Written questions and \nanswers are not an appropriate substitute for an in-person interview of the \ntaxpayer. If the taxpayer or representative will not consent to an interview, then \nthe examiner should either issue a summons for interview or develop the case \nbased on third party contacts. \n(4) Depending on the case, interviews of third parties such as representatives of \nthe donee organization, the appraiser, the baseline study author, or other \n", "91 \n \nconservation experts may be needed. See discussion below on third party \ncontacts. \nC. Property Inspection \n(1) The examiner’s inspection of the property provides valuable information to \nassist in determining whether the conservation easement meets one of the four \nIRC § 170(h)(4) conservation purposes. \n(2) If possible, the examiner should inspect the entire property. Site visitation \nshould be coordinated with the IRS appraiser, whenever possible. If the \nexaminer does not inspect the property, the examiner should contact the IRS \nappraiser to discuss the appraiser’s observations and review pictures obtained \nduring site inspection. Examiners can also research property on Google Maps, \nZillow, or Real Quest. \n(3) If it is not practical to inspect the entire property, the examiner should view \nareas that are relevant to the taxpayer’s claimed conservation purpose and \ndocument the observations. \n(4) Both the interior and exterior of historic properties should be inspected. The IRS \nappraiser generally will need to inspect the interior for purposes of valuing the \nproperty. \n(5) Audit Tip: Depending on the location of the property and time of year, casual \nattire and boots may be necessary. The Examiner may want to consider \nbringing a copy of a map of the property from the baseline report or the \nappraisal as a reference guide during the visit. \n(6) During the inspection, the examiner should note: \n• The location of the significant or protected habitat or species \n• Physical and visual access by the public to the easement property \n• The nature of the surrounding properties and intensity of development in \nthe area \n• The location of buildings and other structures \n• Any post-easement building or land improvements impacting the stated \nconservation purposes \n• Any inconsistent use of the property \n(7) The IRS appraiser will be interested in factors affecting the highest and best \nuse of the property before and after the granting of the conservation easement, \nsuch as zoning or other restrictions on the property, topography or floodplains. \n(8) Ask the taxpayer or representative to point out the outdoor recreation areas, \nanimals, plants, scenic views, or historic land and structures that contribute to \nthe conservation purpose. If the examiner observes an absence of conservation \nattributes, lack of access, de minimis public benefit, or use inconsistent with a \n", "92 \n \nconservation purpose, the examiner should discuss with the taxpayer or \nrepresentative to clarify and solicit additional documentation as warranted. \n• Example: A Wisconsin taxpayer donates a conservation easement with a \nclaimed conservation purpose of protecting the habitat for pheasants, a \nfederally protected species. Pheasants thrive in a habitat of hay fields, \ncropland, and grassland. The examiner observes none of this habitat on \nthe property during the site inspection. \n(9) Audit Tip: “A picture speaks a thousand words.” Consider taking photographs \nand video of the property, the surrounding areas, and the protected habitat or \nspecies, from various public access points with an IRS approved device. The \nIRS appraiser will generally take pictures of the property. \nD. Review of Documents \n(1) The examiner and IRS appraiser will be required to review documents, such as \nthe deed of conservation easement, subordination agreements, baseline study, \nappraisals, contemporaneous written acknowledgment , and information \nprovided by the qualified organization and, in appropriate cases, documents \nsubmitted to the National Park Service. The documents lay the foundation for \ndetermining deductibility. \nD.1. Deed of Conservation Easement \n(1) Conservation easement deeds vary considerably in complexity and length. It is \nimperative that the examiner and appraiser read the deed carefully and have a \nclear understanding of each of the deed’s provisions in order to properly assess \nthe taxpayer’s compliance with the statute and regulations. Program analysts \nand Counsel should be consulted for help. \n(2) Be sure to review a complete and executed copy of the recorded deed including \nattachments. Taxpayers and representatives sometimes provide drafts or \nunexecuted copies. If there are multiple versions, ask for them. Inquire as to the \nchanges made and reasons for the revisions. \n(3) Audit Tip: A copy of an easement deed should be included as part of the \nappraisal report. Compare it to the recorded deed to see if they are the same. If \nnot, discuss with the IRS appraiser as the value of the conservation easement \ncould be impacted. \n(4) In reading the conservation easement deed, the examiner should determine: \n• What property is being encumbered? \n• What is the stated conservation purpose? \n• Does the deed protect the property in perpetuity? \n• What type of public access is allowed to the property? \n• What rights are reserved by the taxpayer? \n", "93 \n \n• What are the provisions for mortgagee subordination and allocation of \nproceeds upon extinguishment? \nD.2. Perpetuity \n(1) Most conservation easement deeds will state that the easement is granted and \nenforceable in perpetuity, but be alert to any provisions contradicting that \nstatement. \n(2) See Chapter 3 for guidance on the perpetuity requirements. \nD.3. Conservation Purpose \n(1) The conservation easement deed should include a specific description of the \nconservation purpose of the particular easement, including, for example, the \nspecies, scenic views, or building being protected. The deed alone is not \nevidence of conservation purpose and must be substantiated by other available \ninformation. \n(2) Audit Tip: In some cases, the conservation purpose as described in the deed \nmerely repeats the conservation purpose definition in IRC § 170(h)(4)(A). The \ntaxpayer must clearly describe and provide documentation to show how the \neasement meets the conservation purpose. \n(3) Except for protection of a relatively natural habitat or ecosystem, conservation \neasements generally must offer either physical access or visual access by the \npublic from a public space such as a highway. Physical access is only required \nif the conservation purpose is for recreation by or education of the general \npublic under IRC § 170(h)(4)(A)(i). When evaluating access, the examiner \nneeds to determine: \n• What access is allowed, by whom, and with what frequency? \n• What portion of the conservation easement can be seen from the highway \nor other public space (if an open space easement for scenic enjoyment)? \n• What impact do reserved rights have on public access? \n(4) For donations of conservation easements on buildings in registered historic \ndistricts, the entire exterior (including the front, sides, rear, and height of the \nbuilding) must be preserved. IRC § 170(h)(4)(B). If the conservation easement \ndeed does not clearly protect the entire exterior, the charitable contribution is \nnot deductible. \n(5) Audit Tip: The term “height” was specifically used in the statute to encompass \nthe donation of space above the historic building. A deed that describes the \nrestriction as the “roof,” would not satisfy the statute absent any additional \nnarrative limiting the “height” of the building. A roof can be raised, and \nadditional floors can be added if the easement merely uses the term “roof.” \n(6) See Chapter 5 for guidance on conservation purpose requirements. \n", "94 \n \nD.4. Reserved Rights \n(1) Taxpayers sometimes reserve rights that can destroy a conservation purpose. \n• Example: The easement calls for the protection of the Virginia running \nbuffalo clover, an endangered plant. However, the deed allows use of all-\nterrain vehicles over the protected land in the area of the clover, which \nwould destroy the clover. This is an inconsistent use, which would result in \ndisallowance of the deduction. Treas. Reg. § 1.170A-14(e). \n(2) Taxpayers are permitted to reserve some development rights on a portion of the \nproperty, such as construction of additional homes or structures, installation of \nutilities, and building of fences or roads, provided that conservation purposes \nare protected. Depending on the facts and circumstances, retention of these \nreserved rights may result in disallowance and need to be reflected in the \nappraisal report and valuation conclusions. \n• Example: A taxpayer claims a charitable contribution deduction for an \nopen space easement but reserves the right to build three residences on \nthe property. The deed does not state the specific location or limit the size \nof the residences. This may raise multiple issues: \n• It may allow for construction of homes that block the public’s scenic \nview, thus permitting destruction of a conservation interest (Treas. \nReg. § 1.170A-14(f) Ex. 3). \n• It may not restrict the use of the property in perpetuity. \n(3) See Chapter 3 and Chapter 5 for guidance on perpetuity and conservation \npurpose requirements. \nD.5. Lender Agreements \n(1) If the property was encumbered by a mortgage or other lien at the time of the \neasement recordation, the taxpayer must obtain a subordination agreement \nfrom the lender prior to the donation of the conservation easement. Palmolive \nBuilding Investors, LLC v. Commissioner, 149 T.C. 380, 394 (2017). \n(2) See Chapter 3 for additional guidance on lender agreements. \nD.6. Subordination Agreements \n(1) A subordination agreement is an agreement by the lender to subordinate its \nrights to the rights of the easement holder to enforce the conservation purposes \nof the donation in perpetuity. Subordination agreements must be recorded in \nthe public record. \n(2) The best way to determine if there are existing mortgages, including home \nequity loans or lines of credit, is by researching public records and interviewing \n", "95 \n \nthe taxpayer. The subordination agreement is generally part of the lender \nagreement attached to the conservation easement deed. \n(3) Audit Tip: Examiners must confirm that timely subordination agreements for all \nliens were recorded in the public record no later than the time the easement is \nrecorded. If the taxpayer did not obtain a subordination agreement before the \ntime of the contribution, the charitable contribution should be disallowed for lack \nof perpetuity. \n(4) Substantial compliance does not apply to failure to properly subordinate. \nMitchell v. Commissioner, 775 F.3d 1243 (10th Cir. 2015). \nD.7. Allocation of Proceeds \n(1) For a charitable contribution deduction to be allowed, at the time of the gift, the \ndonation of the perpetual conservation restriction must give rise to a property \nright immediately vested in the donee organization, which a FMV that is at least \nequal to the proportion that the value of the perpetual conservation restriction at \nthe time of the fit bears to the value of the property as a whole at that time, and \nthat proportion remains constant. If a subsequent unexpected change in the \nconditions surrounding the property that is the subject of a perpetual \nconservation restriction make the continuation of the easement impossible or \nimpractical (e.g., condemnation, casualty, hazard, or accident) the easement \nmay only be extinguished by judicial proceeding. In the event of such an \nextinguishment, at a minimum, the donee must receive its proportion (as \ndetermined when the easement was originally valued) of the extinguishment \nproceeds. \n(2) Audit Tip: Counsel should always be consulted to determine whether the deed \nmeets the allocation of proceeds requirement; improper language in the deed \ncould result in disallowance. See Carroll v. Commissioner, 146 T.C. No. 13 \n(2016), Coal Property Holdings, LLC v. Commissioner, 153 T.C. 126 (2019). \nD.8. Baseline Study \n(1) Under Treas. Reg. § 1.170A-14(g)(5)(i), a baseline study is required if the \ntaxpayer has reserved any right that may impair the conservation purpose. \nTaxpayers almost always reserve these kinds of rights. \n(2) The baseline study is a record of a property’s condition at the time of the \ndonation and is required to substantiate the conservation purpose. It serves two \nsignificant purposes: 1) to satisfy the Treasury Regulations and 2) to assist the \ndonee organization and others in monitoring and enforcing the easement in \nperpetuity. \n(3) The baseline study does not have to be attached to the return or the deed of \nconservation easement, but the donor must provide the study to the donee prior \nto the time the donation is made. If the terms of the donation contain restrictions \nwith regard to a particular natural resource to be protected, the condition of the \n", "96 \n \nresource at or near the time of the gift must be established. A statement saying \nthat the natural resource inventory is an accurate representation of the \nprotected property at the time of the transfer must be signed by the donor and \ndonee. Examiners should obtain a copy of the baseline study (natural resource \ninventory and signed statement) from the taxpayer or donee organization. \n(4) The quality of a baseline study can vary a great deal. Some are detailed, expert \nreports, describing the property’s condition, conservation value, impact of \nreserved rights, and environmental hazards. Some are the taxpayer’s self-\nassessment of the property or the work of a volunteer with little or no \nprofessional credentials. \n(5) A properly documented baseline study is invaluable in helping the examiner \ndetermine if the donation satisfies one of the conservation purposes. A \ncomprehensive baseline study would generally include: \n• A description of the encumbrance \n• A description and map of the conservation characteristics and areas (i.e., \nlisting of identified plants or wildlife) \n• A map or series of maps, drawn to scale, depicting roads, fences, existing \nstructures, trails, water bodies, wetlands, land use history and any other \nproperty features \n• Identification of any reserved building sites \n• Surveys or plat maps \n• Description of any management plans, such as a timber plan \n• On-site photographs possibly including aerial photographs \n• The study author’s name and professional credentials \n(6) The first step in reviewing the baseline study is determining whether the \ntaxpayer was required to secure one. Nearly all easement deeds reserve \nsignificant rights, so nearly all must have a baseline study. \n(7) If the taxpayer is required to have a baseline study, the next step is to ascertain \nwhether the baseline study is sufficient to satisfy the baseline requirements as \noutlined in Treas. Reg. § 1.170A-14(g)(5), including the signed statement by the \ndonor and representative of the donee organization. This statement is an \naffirmation that the baseline study is an accurate representation of the protected \nproperty at the time of transfer. The statement may be incorporated in the \nbaseline study or be a separate document, and it may be included in the deed \nof easement. \n(8) The examiner will also need to assess the credibility of the baseline study. A \nbaseline study prepared by an independent qualified expert such as a \nconservationist, biologist, forester or botanist would generally be given greater \nevidentiary weight than one prepared by a less qualified person or the \n", "97 \n \ntaxpayer’s self-assessment. Also, a baseline study with a lot of documentary \nsupport is more credible than one with little support. \n(9) Examiners will need to confirm that the baseline study is based on accurate \ninformation. In some cases, the IRS will hire outside experts to evaluate the \nbaseline study. Generally, examiners will need to conduct their own research \ncontacting federal, state or local conservation agencies or historic preservation \ngroups as appropriate. Internet research will reveal many useful Internet \nwebsites such as natureserve.org that can help the examiner in evaluating the \nbaseline study. \n(10) \nAudit Tip: Sometimes taxpayers only have a narrative about the general area \nor state without any specific reference to the donated property. These generic \nnarratives do not meet the requirements of Treas. Reg. § 1.170A-14(g)(5). \n(11) \nSee Chapter 5 for guidance on the baseline study requirements. \nD.9. Taxpayer’s Appraisal \n(1) The IRS appraiser has primary responsibility for review of the taxpayer’s \nappraisal to determine if the claimed conservation easement value is correct. \n(2) The examiner should read the appraisal to obtain background information on \nthe property and have a general understanding of the appraisal content and \nmethodology. In consultation with the IRS appraiser, the examiner should \ndetermine if the appraisal was timely and if it meets the requirements of IRC § \n170(f)(11), Notice 2006-96, and Treas. Reg. § 1.170A-13(c). \n(3) See Chapter 7 for guidance on qualified appraisal requirements. \nD.10. Donee Organization \n(1) During the preplanning of the examination, the examiner will generally be able \nto determine whether the donee is an organization eligible to receive tax-\ndeductible contributions. The examiner must also consider whether the donor \nmade any cash payments to the donee, and review the contemporaneous \nwritten acknowledgment. \n(2) The examiner may need assistance from TEGE to determine whether the \ndonee has the commitment to protect the conservation purposes of the \ndonation and has resources to enforce the restrictions of the conservation \neasement. Indication of failure by the donee organization in these areas may \nsuggest the need for a referral to TEGE. \n(3) See Chapter 4 for guidance on qualified organizations. \nD.11. Commitment and Resources \n(1) The taxpayer must transfer the conservation easement to an eligible donee to \nqualify for a contribution deduction. In order to be an eligible donee, the \norganization must be a qualified organization, must have a commitment to \n", "98 \n \nprotect the conservation purpose of the donation and must have the resources \nto enforce the restrictions in the conservation easements. \n(2) Some of the information used to evaluate commitment and resources include: \n• The donee organization’s website \n• The donee organization’s tax returns (Forms 990), obtained from either \nthe Tax Exempt Organization Search on IRS.gov, Guidestar.org, or the \nEconomic Research Institute \n• Interviews of the taxpayer and representatives of the donee organization \n• Observations during the property inspection \n• Property monitoring reports \n• Written agreements between the organization and the taxpayer certifying \nthat the done is qualified and has commitment and resources (required for \ncontributions of easements in registered historic districts) \n(3) If the organization did not meet the commitment and resources tests at the time \nof contribution, no deduction is allowed. A conservation group organized or \noperated primarily or substantially for one of the conservation purposes \nspecified in IRC § 170(h)(4)(A) is considered to have the requisite commitment. \nTreas. Reg. § 1.170A-14(c)(1). \n(4) Audit Tip: Ask for the organization’s monitoring reports to verify whether the \ntaxpayer is in compliance with, and the donee organization is enforcing, the \nterms of the easement. In some cases, donee organizations have allowed \nchanges that were in violation of the terms of the easement. \n(5) Examiners should consult Counsel for assistance if the easement was \nterminated or not being enforced. In addition, a referral to TEGE should be \nconsidered. \nD.12. Cash Payments \n(1) A voluntary transfer of money to a qualified organization is generally deductible \nas a charitable contribution. \n(2) If a taxpayer received goods or services from the organization in exchange for \nmaking the cash contribution, the deduction is limited to the excess of the cash \nover the FMV of the goods and services. Goods and services include cash, \nproperty, services, benefits, or privileges. \n(3) Any cash payment made in conjunction with the conservation easement must \nbe addressed as part of the examination. Examination steps should include an \ninterview of the taxpayer and a review of documents provided by the taxpayer \nand the donee organization. A properly substantiated stewardship fee may be \ndeductible if it meets the requirements of IRC § 170. \n(4) Each case must be decided on the facts and circumstances. \n", "99 \n \n(5) Audit Tip: The Examiner may need to issue a summons to the donee \norganization for relevant documents (including the application, correspondence, \ndonation agreements, processing documents, and other documents relevant to \nthe cash and easement donations). \n(6) Audit Tip: Particularly in syndicated conservation easement transactions, the \ndonation of both the easement and the accompanying cash payment may be \nreported on a short-year return. Just as the Examiner needs to confirm that the \neasement donation was completed during that short year (by checking the date \nthe easement was recorded), the Examiner also needs to confirm that the cash \ndonation was completed during the short year. \nD.13. Contemporaneous Written Acknowledgment \n(1) Section 170(f)(8) states that all cash and noncash contributions of $250 or more \nmust be substantiated with a CWA and lists the requirements for a CWA. It \nmust be obtained by the taxpayer by the earlier of the date the taxpayer filed \nthe return or the due date (including extensions) for the return. The Form 8283, \nNoncash Charitable Contributions (PDF), is not a substitute for a CWA. \n(2) A CWA is required for both the cash payment and the conservation easement. \nExaminers must verify that it was a timely acknowledgment and fully complies \nwith the statutory requirements. Failure to secure a timely or proper CWA \nresults in disallowance of the contribution. \n(3) Note: A CWA must include either a statement that no goods or services were \nprovided (if this was the case) or the value of any goods or services provided. \n(4) Audit Tip: Some taxpayers may argue all that is required is substantial \ncompliance with the CWA requirement. However, because the CWA is \nspecifically required by statute, substantial compliance does not apply. \n(5) Audit Tip: In some cases, the deed itself may satisfy the CWA requirement. In \nBig River Development, LP v. Commissioner, T.C. Memo. 2017-166; 310 Retail, \nLLC v. Commissioner, T.C. Memo. 2017-164; RP Golf, LLC v. Commissioner, \nT.C. Memo. 2012-282; and Averyt v. Commissioner, T.C. Memo. 2012–198, the \ndeed did satisfy the contemporaneous written acknowledgment requirement. \n(6) If the taxpayer makes this argument, this issue should be discussed with \nCounsel. \n(7) See Chapter 6 for guidance on CWA requirements. \nD.14. National Park Service – Form 10-168 \n(1) Congress provided two incentives for historic preservation: (1) the charitable \ncontribution deduction for historic preservation of a historically important land \narea or a certified historic structure under IRC § 170(h) and (2) the rehabilitation \ncredit under IRC § 47. \n", "100 \n \n(2) The Form 10-168 (PDF) must be submitted to the NPS for certification that a \nbuilding in a registered historic district contributes to the district for purposes of \neither tax incentive. Examiners should obtain a copy of the certification and any \nrelated documents from the taxpayer or the NPS. \n(3) Even if the property is certified by the Secretary of Interior, it does not mean the \ncharitable contribution deduction is allowable. The IRS is responsible for all \nlegal determinations concerning the tax consequences. 36 CFR § 67.1. \n(4) Part I of the Form 10-168, used for certification of the building for historic status, \ndetails the condition of the building at the time of the application. Part II is a \nnotice of proposed work and generally includes information such as: \n• Date of application \n• Description of the condition of the building and any proposed work \n• The expected start and completion dates \n• Estimated costs \n• Architectural drawings \n(5) Part II is required for any rehabilitation project whether the property is \nindividually listed on the National Register of Historic Places or in a registered \nhistoric district. \n(6) In some cases, taxpayers have improperly claimed a charitable contribution \ndeduction for the contribution of development rights that they retained. \n(7) Section 47 permits the rehabilitation tax credit to be claimed only by owners \nand, in some instances, lessees if certain statutory requirements are met. If the \ntaxpayer does not own all of the interests in real property to which the \nrehabilitation relates (and is not a lessee), the taxpayer is not entitled to the \nentire rehabilitation tax credit. Generally, no tax credit is permitted for property \nthat the taxpayer does not own. See Villa v. Commissioner, T.C.M. 1980-305; \nDavenport v. Commissioner, T.C.M. 1977-34); Schaevitz v. Commissioner, \nT.C.M.1971-197 and Bailey v. Commissioner, 88 T.C. 1293 (1987). \n(8) Audit Tip: Contact Counsel in rehabilitation project cases. Resources and \ncontacts for the Rehabilitation Credit are available on the IRS Virtual Library. \n(9) Being listed on the National Register of Historic Places or located in a \nregistered district imposes no restrictions on the property. Only local law can \nimpose restrictions. A local historic district may not have the same boundaries \nas the National Register District by the same name. Thus, a building may be \ncertified for purposes of a charitable contribution deduction by the NPS but the \nonly restrictions prior to the easement might be local zoning. \n(10) \nAudit Tip: Be sure to determine whether there are restrictions under local \npreservation law. A building added to the National Register of Historic Places \nmay or may not be subject to local restrictions. \n", "101 \n \nD.15. Partnership Documents \n(1) Examiners should carefully review partnership agreements and other \ndocuments when present in any easement case. A partnership arrangement \nwas used to transfer state rehabilitation tax credits in Virginia Historic Tax \nCredit Fund 2001 LP v. Commissioner, 693 F.3d 129 (4th Cir. 2011). The \nFourth Circuit Court of Appeals held that the transfer of the state tax credit was \na disguised sale. The partnership structure and partnership agreement are of \nparticular importance in a syndicated conservation easement case because the \npartnership relies on the contributing partner’s holding period to generate the \ndeduction. Some cases involve multiple layers of partnerships. In addition to \nthe partnership agreement, the partnership may use other materials including a \nPrivate Placement Memorandum, operating agreement, and articles of \norganization. All partnership materials should be reviewed thoroughly. \nExaminers should determine the relationship between the various entities and \nconsider whether the transaction is respected for tax purposes as well as \nwhether the partners are bona fide, meaning that they each share meaningfully \nin the economic returns of the activity. \nE. Third-Party Contacts \n(1) Development of a conservation easement case frequently requires contact with \nthird-parties for additional facts or confirmation of information obtained during \nthe course of the examination. Examples of possible third-party contacts \ninclude: \n• Donee organization \n• Mortgage lenders \n• Appraisers \n• Local government officials \n• Real estate agents \n• State and federal conservation agencies \n• Prior and subsequent owners of the encumbered property \n(2) Examiners must adhere to procedures for making third-party contacts as \noutlined in IRM, Section 4.11.57, Third Party Contacts; IRM 25.27.1, Third-Party \nContact Program. Advance notification of potential third-party contacts during \nan examination is required. The examiner must provide Letter 3164 to the \ntaxpayer and must wait 45 days from the issuance of the letter before \ncontacting the third party. There are multiple letters in the 3164 series. \nTypically, Letters 3164-E, F and G are used in a conservation easement audit. \n(3) IRC 7602(c) Notice of Contact of Third Parties, does not apply to any contact \nwith any office of any local, state, federal or foreign entity unless the contact is \n", "102 \n \nconcerning the taxpayer’s business with the government office contacted, such \nas the taxpayer’s contracts with, or employment by the office. See IRM Section \n4.11.57.4.2.5 for additional guidance. \n(4) Form 12180, Third-Party Contact Authorization Form, or Letter 1995, Third \nParty Contact Letter to Request Information, is used to solicit records. Some \ncases may require use of an administrative summons (Form 2039). \n(5) Audit Tip: While the examiner is required to notify the taxpayer of the intent to \nmake a third-party contact and wait 45 days, there is no requirement to obtain \nthe taxpayer’s permission prior to making a third-party contact. \nE.1. Donee Organizations \n(1) Third-party contacts may be warranted with key representatives of the donee \norganization. Individuals involved in drafting the easement deed or who were \npoints of contact may have important information on the transactions. Consider \nseparate interviews of all third parties. Typically, these interviews can be done \nby telephone. \n(2) Audit Tip: Examiners should request the organization's entire file including all \ncorrespondence for this donation and any other donation by the taxpayer. \n(3) Donee organizations may want a summons before consenting to release of \nrecords. \nE.2. Mortgage Lenders \n(1) Mortgage lender files are a valuable source of information about the \nsubordination, allocation of proceeds, and valuation of the conservation \neasement. \n(2) If the bank agreed to the subordination, the lender’s file may include \ncorrespondence or other information from the taxpayer or the donee \norganization describing the impact of the conservation easement on the value \nor use of the property. Examiners should obtain explanations for any \ninconsistent statements made to third parties. \n• Example: Correspondence from the donee organization to the lender \nsoliciting a subordination agreement includes statements that the \nconservation easement has no impact on the value of the property. \n(3) If the taxpayer secured a mortgage or refinancing around the time of the \neasement donation, an appraisal may have been obtained by the lender. The \nappraisal coupled, with information on the loan application, may be helpful in \nevaluating the reasonableness of the claimed value of the easement. \n• Example: The taxpayer granted a conservation easement on December \n27, 2019, claiming a loss in value on the property of $23 million. The \ntaxpayer’s appraised before value of the property was determined to be \n$25 million with an after value of $2 million. The taxpayer obtained a \n", "103 \n \nmortgage loan on January 27, 2020. The bank’s appraisal reports a value \nof $20 million after considering the impact of the conservation easement \non the property. This suggests that the taxpayer overvalued the easement. \n(4) The taxpayer’s loan application and related appraisals can also be useful in \ndetermining whether the taxpayer made a good faith investigation of the value \nof the easement. This is relevant to imposition of penalties. \n• Example: Using the example above, suppose the taxpayer showed the \nvalue of the property on his loan application as $24 million. If the taxpayer \nbelieved his property lost $23 million in value due to the donation of the \neasement, why was the “alleged” $2 million after value not reported on the \nloan application? \n(5) A summons will generally be required to obtain the loan file information. \nE.3. Appraiser \n(1) An interview of the taxpayer’s appraiser should generally be conducted by the \nIRS appraiser. The examiner should also participate. \n(2) It may also be necessary to obtain the taxpayer’s appraiser’s work file. Most \nlicensed appraisers are required to maintain a work file in accordance with state \nlicensing requirements. The appraiser’s work file may include communications \nbetween the taxpayer and donee organization or may reveal the existence of \nmultiple versions of the appraisal. \n(3) The examiner or the IRS appraiser should determine if there were multiple \nversions of the appraisal and if so, secure copies and the reasons for them. \nE.4. Federal and State Conservation Agencies \n(1) To find out about the physical characteristics of the subject property and the \neasement’s conservation purposes, examiners may want to contact various \nfederal and state conservation agencies, including but not limited to: \n• NPS \n• U.S. Fish and Wildlife Service \n• U.S. Environmental Protection Agency \n• U.S. Department of Agriculture \n• U.S. Army Corps of Engineers \n• State Departments of Natural Resources \n(2) These agencies may have information on the specific property or on the area in \ngeneral. \nE.5. Local Government Officials \n", "104 \n \n(1) Local preservation boards and officials responsible for zoning and building \npermits are good sources of information. If possible, secure copies of pertinent \nrecords and speak directly to the officials. Evidence of quid pro quo may be \nfound by talking to local officials and reviewing records including minutes of \nmeetings. \n(2) Audit Tip: If the conservation easement is part of subdivision development, \nrequest assistance from the IRS appraiser in reviewing documents such as \nplats, maps, etc. \nE.6. Real Estate Agents \n(1) Local real estate agents can be valuable third-party contacts, having knowledge \nof property values, sales, and local market conditions, including sales of \nproperties encumbered by easements. \n(2) Audit Tip: If the property was purchased or sold shortly before or after the date \nof the contribution, the real estate agent may be able to provide useful \ninformation as to the value of the property or impact of the conservation \neasement. \nE.7. Property Owners \n(1) Prior or subsequent owners of the subject property can provide information \nuseful in determining the value of the property such as physical condition, \npreexisting restrictions or encumbrances and other specific attributes. \n(2) Audit Tip: If the property was sold subsequent to the granting of the easement, \nconsider contacting the buyer to determine the impact (if any) on the purchase \nprice paid. Buyers are sometimes unaware of the easement or may indicate the \neasement had no impact on the purchase price. \nXIII. Concluding the Examination \nA. Overview \n(1) The examiner must determine whether the taxpayer meets all of the \nrequirements to claim a charitable contribution deduction for the conservation \neasement. While the process of issue identification begins in the preplanning \nstages of the examination, a conclusion as to the deductibility of the \nconservation easement can only be made after considering all of the \ninformation obtained during the examination. \n(2) In addition to identifying legal issues, examiners, generally with the assistance \nof a valuation expert, will determine if the conservation easement has been \nproperly valued. \n(3) Preparation of a quality examination report is a critical component of the \nexamination process. The examiner will need to include a comprehensive \nexplanation of the facts, law, and conclusions, incorporating the IRS appraiser’s \nwork product and attaching relevant exhibits. If the examination results in a \n", "105 \n \nproposed adjustment, the examiner must consider whether penalties are \napplicable and who is liable for the penalties. \n(4) During the closing conference, the examiner should explain the bases for any \nproposed adjustments to the charitable contribution deduction and proposed \npenalties. In unagreed cases, the examiner will need to verify that the \ntaxpayer’s protest complies with the requirements as outlined in Publication 5, \nYour Appeal Rights and How to Prepare a Protest If You Don’t Agree (PDF) \nand to prepare a rebuttal to the protest as warranted. \nB. Issue Identification \n(1) The examiner and IRS appraiser must have a comprehensive understanding of \nall of the legal requirements and the value of the conservation easement in \norder to make a decision on deductibility of the contribution. \n(2) The Internal Revenue Code, Treasury Regulations, publications, and this ATG \nare tools to help in the identification of potential issues. Program analysts and \nCounsel can also be consulted for assistance. \n(3) An Issue Identification Worksheet has been developed as a job aid to help \nexaminers with issue analysis. The worksheet is not all-inclusive but is a \nsummary of key issues. See Exhibit 13-1. \n(4) Besides examining all aspects of the conservation easement deduction issue, \nexaminers must also examine whether other costs associated with the \nconservation easement contribution were properly reported. \n(5) Audit Tip: Taxpayers will sometimes improperly claim the appraisal fees and \nother costs as cash contributions. Appraisal fees are deductible only as \nmiscellaneous deductions subject to a 2% adjusted gross income limitation \nunder IRC § 67, and, even then, are not deductible for any taxable year \nbeginning after December 31, 2017, and before January 1, 2026. \nB.1. Substantial Compliance \n(1) The burden is on taxpayers to establish they have complied with all statutory \nrequirements to substantiate the charitable contribution claimed under IRC § \n170. INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992). Moreover, a \ncharitable contribution is allowed as a deduction only if verified under the \nTreasury Regulations. IRC § 170(a)(1). \n(2) In cases where the disallowance is based in whole or in part on noncompliance \nwith the substantiation rules, taxpayers and their representatives may argue \nthat they have substantially complied, based on a judicial doctrine called \n“substantial compliance.” Bond v. Commissioner, 100 T.C. 32, 40–41 (1993). \n(3) Under prior law, some courts have allowed a deduction for a taxpayer who has \nsubstantially, but not strictly, complied with “directory” regulations governing tax \nelections and deductions. See Bond v. Commissioner, 100 T.C. 32, 40-41 \n(1993). The tax court has ruled that a taxpayer substantially complies with the \n", "106 \n \nregulations when the taxpayer had “provided most of the information required, \nand the single defect in furnishing everything required was not significant.” \nHewitt v. Commissioner, 109 T.C. 258, 265 (1997). \n(4) It is important to note that Bond, Hewitt, and Simmons v. Commissioner, T.C. \nMemo. 2009-208, were based on law in effect prior to the enactment of the \nPension Protection Act (2006), which imposes new mandatory statutory \nrequirements for qualified appraisals. \n(5) In Costello v. Commissioner, T.C. Memo. 2015-87, the tax court declined to \napply the substantial compliance doctrine where the taxpayer’s appraisal valued \na fee simple interest “before and after a hypothetical sale of development rights” \ninstead of a conservation easement. The tax court stated that an appraisal of \nthe wrong asset cannot substantially comply with the regulations because the \nappraisal in that case prevents the Commissioner from properly understanding \nand calculating the claimed deduction. \n(6) The tax court has stated that the substantial compliance doctrine should not be \nliberally applied. Alli v. Commissioner, T.C. Memo 2014-15. Compliance is not \nsubstantial if an appraisal fails to meet the essential requirements of the \ngoverning statute. Cave Buttes, LLC v. Commissioner, 147 T.C. 338, 350 \n(2016). The substantial compliance doctrine should only be used to forgive \n“minor discrepancies in the taxpayer’s reporting.” Kaufman v. Shulman, 687 \nF.3d 21, 22 (1st Cir. 2012). \n(7) A failure to comply with the contemporaneous written acknowledgment \nrequirement of IRC § 170(f)(8) cannot be excused by the substantial \ncompliance doctrine. Izen v. Commissioner, 148 T.C. 71, 77 (2017); Boone \nOperations Co. LLC. v. Commissioner, T.C. Memo. 2013-101. However, the tax \ncourt determined that a deed of easement may constitute a contemporaneous \nwritten acknowledgment in 310 Retail, LLC, v. Commissioner, T.C. Memo. \n2017-164 and in Big River Development v. Commissioner, T.C. Memo 2017-\n166 as long as the deed satisfies the requirements of § 170(f)(8). \n(8) A refusal to report the cost basis and date of acquisition on the donated \nproperty on Form 8283 does not substantially comply with the regulatory \nrequirement. Belair Woods, LLC v. Commissioner, T.C. Memo. 2018-159. \nWhere a taxpayer’s Form 8283 has “simply too many omissions to overlook or \nto categorize as inadvertent” it cannot be said to have substantially complied. \nBrannan Sand & Gravel Co., LLC v. Commissioner, T.C. Memo. 2020-76. \nC. Report Writing \n(1) The examiner’s report is the principal means of informing to the taxpayer, IRS \nIndependent Office of Appeals (Appeals), and Counsel of the reasons for \nproposed adjustments to the conservation easement deduction. Typically, \nconservation easement issue reports take a significant amount of time to \nprepare. Unagreed reports should be prepared in accordance with IRM section \n", "107 \n \n4.10.8.12, Unagreed Case Procedures (SB/SE Field and Office Examiners \nOnly). \n(2) See Chapter 14 and IGM SBSE-20-0520-0029,Timing of Supervisory Approval \nwith Respect to IRC 6751(b)(1), for more information about timing of \nsupervisory approval for penalties. \n(3) The explanation of items, whether presented in a lead sheet format or on Form \n886-A, Explanation of Items, will be fact intensive, describing all details of the \ntransaction, the tax law, and the bases for any proposed adjustment. There may \nbe a number of exhibits including the appraisal, an appraisal review, the \nconservation easement deed (with recording date), lender agreement, the \ncontemporaneous written acknowledgment, baseline, and other pertinent \ndocuments. \n(4) If the lead sheet work papers are used for the unagreed report, extraneous \ninformation (e.g., work paper cross-referencing, audit steps, etc.) that would be \nof no use to the taxpayer or representative should be removed prior to the \nissuance of the report. \n(5) In many cases in which an adjustment is proposed, there will be more than one \nlegal theory for the proposed adjustment (in addition to valuation). The legal \nissues are generally the primary position, and valuation serves as an alternative \nposition. \n(6) Audit Tip: It is very important that the report clearly articulate and address all \nissues and include relevant exhibits. Appeals will generally not consider bases \nfor the adjustment if not addressed in the unagreed report. \nC.1. Job Aids \n(1) Report writing job aids are available on the IRS Virtual Library page. These \naids, while intended to help streamline the report writing process, must be \ncustomized to address the facts and circumstances of each case. \n(2) The job aids provide a sample presentation format including facts, applicable \ntax law, analysis, and conclusions. The examiner will need to check the most \ncurrent edition of the IRC, Treasury Regulations, case law, and published \nguidance to be sure that there have not been any changes since the date of the \njob aid. \n(3) The Facts section of the job aid serves as an example of the extent and type of \ninformation that should be included in the report. \n(4) The Law section contains a summary of conservation easement tax law. It was \nprepared in consultation with Counsel and generally is used verbatim in all \nreports, but examiners should update for any new case law decisions and \nstatutory changes. \n(5) The Analysis and Conclusion section will also be case specific, but this material \nmay be used to assist with drafting of the examiner’s conclusions. A discussion \n", "108 \n \nof substantial compliance included in this section should be incorporated into all \nunagreed reports. \nC.2. Valuation Expert Reports \n(1) The IRS appraiser’s or outside fee appraiser’s report or review must be \nattached as an addendum to the examiner’s unagreed report. \n(2) Audit Tip: Notate on the Examiner Case Activity Record (Form 9984) and in \nthe Report Transmittal (Form 4665) that a complete copy of the IRS appraiser \nreport was provided to the taxpayer so there will be no question that the \ntaxpayer received a copy. It is also a good idea to mention this in the report \nnarrative. \nC.3. Penalties \n(1) The application of penalties is based on the facts and circumstances of each \ncase. There is no statutory authority to waive applicable penalties unless the \ntaxpayer can establish that the reasonable cause exception, to the extent \napplicable to accuracy-related and other penalties, applies. The reasonable \ncause exception is not available for gross valuation misstatements. IRC § \n6664(c)(3). \n(2) A separate lead sheet or Form 886-A will be needed if there are any proposed \npenalties. \n(3) Throughout the examination, the examiner should be developing relevant facts \nto determine which penalties may apply and whether there is reasonable cause \nfor any of the otherwise applicable penalties. Examiners are required to \nconsider penalties, document their determination, and obtain written approval \nby their immediate supervisor of any determination to seek a penalty in all \ntaxpayer examinations. See IRC § 6751(b)(1). \n(4) See Chapter 14 and IGM SBSE-20-0520-0029, Timing of Supervisory Approval \nwith Respect to IRC 6751(b)(1), for more information about timing of \nsupervisory approval for penalties. \n(5) Audit Tip: Do not wait until the end of the audit to think about penalties. \nConsideration of penalties and gathering of information should be done \nthroughout the examination, beginning with the preplan. Interviews of the \ntaxpayer and third parties may be required to obtain all necessary facts. \n(6) The penalty report for a conservation easement case will generally include a \ntiering of proposed penalties with multiple alternative positions, starting with \nvaluation misstatements, then substantial understatement, and finally \nnegligence. \n(7) A discussion of reasonable cause must be incorporated into the penalty write-\nup. \n", "109 \n \n(8) Audit Tip: Examiners should be alert to any indication of fraud and should \nconsult the Fraud Enforcement Advisor if badges of fraud are identified during \nthe examination. \n(9) See Chapter 14 for detailed discussion of penalties and reasonable cause. \nC.4. Technical Assistance \n(1) Program analysts and Counsel attorneys assigned to this issue are available to \nprovide assistance and feedback with respect to unagreed reports. Contacts \ncan be found on the IRS Virtual Library page. \nD. Closing Conference \n(1) A closing conference is normally held with the taxpayer or representative. The \npurpose of the conference is to explain the bases for any proposed adjustments \nto the charitable contribution deduction and proposed penalties, confirm the \naccuracy of the facts, gather new information, and obtain a preliminary \nresponse from (or on behalf of) the taxpayer. \n(2) The examiner may want to provide a draft report to the taxpayer or \nrepresentative in advance of the meeting or at the conference. Since valuation \nis a significant issue in most conservation easement cases, it is recommended \nthat the IRS appraiser participate in the conference. \nE. Taxpayer Protests \n(1) Taxpayers will generally need to file a formal written protest in order to exercise \nappeal rights. If the total amount of tax for any tax period is less than $25,000, a \nsmall case request can be submitted instead of a formal written protest. \n(2) Publication 5, Your Appeal Rights and How to Prepare a Protest If You Don’t \nAgree (PDF), outlines the specific information that must be included in a formal \nprotest. The taxpayer or representative must provide a list of changes they do \nnot agree with, the facts supporting their position, and the authority they are \nrelying upon. \n(3) A protest is not adequate if it does not comply with the requirements as \ndescribed in Publication 5. A taxpayer’s general statements without a clear \nexplanation and without citing any legal basis for disagreement is generally not \nsufficient. \n(4) Letter 1025, Letter of Protest, is mailed to the taxpayer if the protest is \ndetermined to be inadequate. Unless the group manager agrees to an \nextension, if the taxpayer fails to provide a complete protest within 10 days, the \ncase should be closed for Statutory Notice of Deficiency, Final Partnership \nAdministrative Adjustment, or Notice of Final Partnership Adjustment. \nE.1. Rebuttals to Taxpayer Protest \n", "110 \n \n(1) If there is new or contradictory information in the protest, the examiner may \nneed to request additional information from the taxpayer or prepare a rebuttal to \nsupplement the unagreed report. \n(2) The examiner should provide a copy of the protest to the IRS appraiser so the \nappraiser can provide a written rebuttal for issues within the scope of his or her \nresponsibilities (such as qualified appraisal, qualified appraiser, or valuation). \nThe IRS appraiser’s rebuttal may be incorporated into a single rebuttal or as an \naddendum to the examiner’s rebuttal. \n(3) A copy of the rebuttal, including the IRS appraiser’s rebuttal, should be provided \nto the taxpayer. \nF. Exhibit 13-1 Conservation Easement Issue Identification \nWorksheet \n(1) NOTE: This worksheet is not an all-inclusive list of potential issues for \ndonations of conservation easements. Users should review IRC § 170, DEFRA \n§ 155, the corresponding Treasury Regulations, Notice 2006-96 and case law. \n \n \nGeneral Contribution Deduction Issues Code/Regs/Other \nLack of charitable intent (including receipt \nof quid pro quo) \nIRC § 170(a) \nTreas. Reg. § 1.170A-1(h) \nConditional gift \nTreas. Reg. § 1.170A-1(e) \nTreas. Reg. § 1.170A-7(a)(3) \nContemporaneous written \nacknowledgment \nIRC § 170(f)(8) \nTreas. Reg. § 1.170A-13(f) \nTreas. Reg. § 1.170A-16(b) \nSubstantiation and reporting requirements \n \n \n \nIRC § 170(f)(11) \nTreas. Reg. § 1.170A-13(c) \nTreas. Reg. § 1.170A-16(d)-(f) \n Qualified Appraisal Issues \n Code/Regs/Other \n \n(Note: The Deficit Reduction Act of 1984 \n(DEFRA) and § 170(f)(11) \noutline the statutory appraisal \nrequirements.) \nIRC § 170(f)(11) \nDEFRA §§ 155(a)(1)(A) and (a)(4) \nTreas. Reg. § 1.170A-13(c)(3) \nTreas. Reg. § 1.170A-16(e)(1)(iv) \nNotice 2006-96, Section 3 \n", "111 \n \nAppraisal not attached to return (FMV \n>$500K) \nIRC § 170(f)(11)(D) \nAppraisal not prepared in accordance with \ngenerally accepted appraisal standards \nIRC § 170(f)(11)(E)(i)(II); \nTreas. Reg. § 1.170A-17(a) \nNotice 2006-96, Section 3.02(2) \nAppraisal not timely \nTreas. Reg. § 1.170A-13(c)(3)(i)(A) \nTreas. Reg. § 1.170A-17(a)(4) \nNot a qualified appraiser \nIRC § 170(f)(11)(E)(ii) \nTreas. Reg. 1.170A-13(c)(3)(i)(B) \nTreas. Reg. 1.170A-13(c)(5) \nTreas. Reg. 1.170A-17(b)(1) \nNotice 2006-96, Section 3.03 \nDoesn’t meet IRC, DEFRA, or Treas. \nReg. requirements \nDEFRA § 155; § 170(f)(11)(E)(i)(I) \nTreas. Reg. § 1.170A-13(c)(3) \nNotice 2006-96 \nAppraisal fee based on percentage of \nvalue \nTreas. Reg. § 1.170A-13(c)(3)(i)(D) \nTreas. Reg. § 1.170A-13(c)(6) \nTreas. Reg. § 1.170A-17(a)(9) \nForm 8283 (appraisal summary) missing \nor incomplete \nDEFRA § 155(a)(1)(B) \nDEFRA § 155(a)(3) \nTreas. Reg. § 1.170A-13(c)(4) \nTreas. Reg. § 1.170A-16(d)(iii) \nTreas. Reg. § 1.170A-16(f) \nQualified Real Property Interest Issues Code/Regs/Other \nQualified real property interest \nIRC § 170(h)(2) \nTreas. Reg. § 1.170A-14(a) and (b) \nLack of perpetuity \nIRC § 170(h)(2)(C) \nIRC § 170(h)(5) \nLack of perpetuity - Failure to properly \nsubordinate \nTreas. Reg. § 1.170A-14(g)(2) \nLack of perpetuity - Extinguishment- \nallocation of proceeds \nTreas. Reg. § 1.170A-14(g)(6)(ii) \nNot a qualified organization or eligible \ndonee \nIRC § 170(h)(3) \nTreas. Reg. § 1.170A-14(c)(1) \nConservation Purpose Issues \nCode/Regs/Other \nConservation purpose \nIRC § 170(h)(4) \nTreas. Reg. § 1.170A-14(d) \nOutdoor recreation or education of public IRC § 170(h)(4)(A)(i) \nTreas. Reg. § 1.170A-14(d)(2) \nOutdoor recreation or education of public \n- Lack of access \nTreas. Reg. § 1.170A-14(d)(2)(ii) \n", "112 \n \nProtection of environmental system \n(natural habitat) \nIRC § 170(h)(4)(A)(ii) \nTreas. Reg. § 1.170A-14(d)(3) \nProtection of environmental system - \nSignificant habitat or ecosystem \nTreas. Reg. § 1.170A-14(d)(3)(ii) \nPreservation of open space \nIRC § 170(h)(4)(A)(iii) \nTreas. Reg. § 1.170A-14(d)(4) \nPreservation of open space -Scenic \nenjoyment \nIRC § 170(h)(4)(A)(iii)(I) \nTreas. Reg. § 1.170A-14(d)(4)(ii) \n \n \nPreservation of open space - \nGovernmental conservation policy \nIRC § 170(h)(4)(A)(iii)(II) \nTreas. Reg. § 1.170A-14(d)(4)(iii) \nPreservation of open space -\nGovernmental conservation policy - \nPhysical or visual access required if \nconservation purpose is frustrated without \naccess \n \nTreas. Reg. § 1.170A-14(d)(4)(iii)(C) \nPreservation of historic land or certified \nhistoric structure \nIRC § 170(h)(4)(A)(iv) \nTreas. Reg. § 1.170A-14(d)(5) \nPreservation of historic land or certified \nhistoric structure - Historic land \nTreas. Reg. § 1.170A-14(d)(5)(ii) \nPreservation of historic land or certified \nhistoric structure - Certified historic \nstructure \nTreas. Reg. § 1.170A-14(d)(5)(iii) \nPreservation of historic land or certified \nhistoric structure - Certified historic \nstructure \n(1) Individually listed or (2) in historic \ndistrict and NPS certifies \nIRC § 170(h)(4)(C) (donations made after \n8/17/06) \nTreas. Reg. § 1.170A-14(d)(5)(iii) \nPreservation of historic land or certified \nhistoric structure - Lack of visual access \nTreas. Reg. § 1.170A-14(d)(5)(iv)(A) \nFailure to comply w/ PPA for buildings not \nindividually listed. (façade only) \nIRC § 170(h)(4)(B) \nFailure to comply w/ PPA for buildings not \nindividually listed - No restriction for entire \nexterior. \n \nIRC § 170(h)(4)(B)(i) \nFailure to comply w/ PPA for buildings not \nindividually listed - Lack of donor/donee \nwritten agreement: re donee’s \nqualifications. \n \nIRC § 170(h)(4)(B)(ii) \n", "113 \n \nFailure to comply w/ PPA for buildings not \nindividually listed - Failure to attach \nappraisal, with photos and description of \nrestrictions. \n \nIRC § 170(h)(4)(B)(iii) \nFailure to comply w/ PPA for buildings not \nindividually listed - Failure to pay \n$500 filing fee (façade only) \n \nIRC § 170(f)(13) \nNot exclusively for conservation purpose IRC § 170(h)(5) \nTreas. Reg. § 1.170A-14(e) \nNot exclusively for conservation purpose Treas. Reg. § 1.170A-14(e)(2) and (3) \nConservation Purpose Issues \nCode/Regs/Other \n \nInconsistent Use \nTreas. Reg. 1.170A-14(e)(2) and (3) \nInsufficient or lack of documentation for \nconservation purpose (baseline study) \nTreas. Reg. § 1.170A-14(g)(5)(i) \nTreas. Reg. §; 1.170A-13(c)(4)(ii)(M) \nValuation Issues \nCode/Regs/Other \nOvervaluation \nIRC § 170(a) \nTreas. Reg. § 1.170A-14(h)(3) \nDeduction not based on FMV \nIRC § 170(a) \nTreas. Reg. § 1.170A-1(c) \nTreas. Reg. § 1.170A-14(h)(3) \nDeduction limited to basis \nIRC § 170(e)(1)(A) Contiguous \nParcel/noncontiguous parcel \nTreas. Reg. § 1.170A-14(h)(3)(i) \nAggregate partnership investment in an \nalmost contemporaneous transaction \nindicates the before value of the \nconservation easement \nPlateau Holdings, LLC v. Commissioner, \nT.C. Memo. 2020-93. \nTOT Property Holdings, LLC v. \nCommissioner, TC Docket No. 5600-\n17 (unpublished bench op., Nov. 22, 2019). \nMiscellaneous Issues \nCode/Regs/Other \n \nPercentage limitations not computed \nproperly \nIRC § 170(b) \nRehabilitation credit-reduction of \ndeduction \n(façade only) \nIRC § 170(f)(14) \nRehabilitation credit-recapture (façade \nonly) \nIRC § 50(a) \nRev. Rul. 89-90 \n", "114 \n \nPartnership anti-abuse rule \nTreas. Reg. § 1.701-2 \nCodified Economic Substance Doctrine \nIRC § 7701(o) \n \nJudicial Doctrines \nCode/Regs/Other \n \nStep Transaction \n See Chapter 10 \nSubstance over Form Doctrine \n \n See Chapter 10 \nLack of bona fide partner and partnership See Chapter 10 \nPenalties and Penalty Issues \nCode/Regs/Other \n \nTaxpayer Penalties \n \nAccuracy-Related \nIRC § 6662(b)(1), (b)(2), (b)(3), (b)(6), (h), \n(i) \n \nAccuracy-related – reportable transaction \nunderstatement \nIRC § 6662A(a), (c) \nFailure to disclose participation in \nreportable transaction \nIRC § 6707A \nTreas. Reg. § 301.6707A-1 \nFraud Penalty \nIRC § 6663 \nReasonable Cause \nIRC § 6664(c) \nOther Penalties \n \nAppraiser penalty \nIRC § 6695A \nTax Return Preparers \nIRC § 6694 \nPromoting Abusive Tax Shelters \nIRC § 6700 \nAiding and Abetting Understatement of \nTax \nIRC § 6701 \nFailure to disclosure- material advisor \nIRC § 6707 \nFailure to maintain list of advisees with \nrespect to reportable transaction \nIRC § 6708 \nXIV. Penalties \nA. Overview \n(1) Penalties exist to encourage voluntary compliance by supporting the standards \nof behavior required by the IRC. Examiners are required to consider penalties \nand document their determination (and obtain written approval by their \nimmediate supervisor of an initial determination to seek a penalty in all taxpayer \nexaminations. See IRC § 6751(b)(1) and Interim Guidance Memorandum \nSBSE-20-0520-0029 directing examiners when to secure penalty, approval. \n", "115 \n \n(2) All facts and circumstances must be developed during the examination to \ndetermine what penalties (if any) are appropriate. Penalties may be imposed on \nthe taxpayer, return preparer, appraisers and other tax advisors. \n(3) See the IRM 20.1, Penalty Handbook, for additional guidance on penalties. \nB. Introduction to Penalty Approval \n(1) Nearly every penalty worked in a field audit requires proper, writing supervisory \napproval prior to asserting that penalty. IRC § 6751(b)(1). The only penalties \ndetermined in the field that do not require supervisory approval under IRC § \n6751(b)(1) are the additions to tax under IRC §§ 6651, 6654, and 6655. \n(2) Each penalty determined in an examination must be properly approved, unless \nspecifically excepted under IRC § 6751(b)(2). Palmolive Building Investors, LLC \nv. Commissioner, 152 T.C. 75, 82-87 (2019). Therefore, if an examiner \ndetermines the gross valuation misstatement penalty applies, but alternatively \nasserts the negligence penalty, substantial understatement of income tax \npenalty, and substantial valuation misstatement penalty, the examiner must \nsecure written supervisory approval for each of these four penalties. Multiple \npenalties may be approved on the same form. Belair Woods, LLC v. \nCommissioner, 154 T.C. No. 1(2020). Even assessable penalties, such as IRC \n§ 6707A penalties for failures to include reportable transaction information with \na return, must be approved. Laidlaw’s Harley Davidson Sales, Inc. v. \nCommissioner, 154 T.C. No. 4, slip op. at 19 (Jan. 16, 2020). \n(3) Supervisory approval under section 6751(b)(1) should take the proper form and \nevidence approval by the proper person at the proper time. \n• Penalty approval must be in writing. IRC § 6751(b)(1). All examinations \nin which a penalty is asserted should include a completed and signed Civil \nPenalty Approval Form under the 300 tab. Legally, a penalty may be \napproved in writing through other means. For example, a penalty may be \napproved by signing the cover letter to a summary report, if the subject \npenalty is included in that summary report. PBBM-Rose Hill, LTD. v. \nCommissioner, 900 F.3d 193, 213 (5th Cir. 2018). \n• Penalty approval must also be secured from the proper individual. To \nbe acceptable approval, the immediate supervisor of the individual who \ninitially determined the penalty must provide the written approval. IRC § \n6751(b)(1); Palmolive Building Investors, LLC v. Commissioner, 152 T.C. \n75, 82-87 (2019). \n• Note: Different employees can determine different penalties within the \nsame examination. However, if separate employees determine \ndifferent penalties in the same examination, then each individual must \nhave their immediate supervisor approve the penalties they \ndetermined. Palmolive Building Investors, LLC v. Commissioner, 152 \nT.C. 75, 84-85 (2019). For example, if Revenue Agent A determines \n", "116 \n \nthat the negligence penalty applies to the taxpayer’s 2015 Form 1120, \nand Revenue Agent B determines that the substantial understatement \nof income tax penalty applies to the Taxpayer’s 2015 Form 1120, then \nRevenue Agent A’s immediate supervisor must approve the \nnegligence penalty and Revenue Agent B’s immediate supervisor \nmust approve the substantial understatement of income tax penalty. \nAn acting supervisor may approve a penalty. Blackburn v. \nCommissioner, 150 T.C. 218, 220, 224 (2018). \n• Note: A penalty may be determined by an examiner, an Appeals \nOfficer, or Counsel. Roth v. Commissioner, T.C. Memo. 2017-248, at \n8-12. Therefore, if you are working with Counsel on a case and they \nrecommend a penalty, make sure that the Counsel employee secures \ntheir immediate supervisor’s written approval. If an examiner’s \nmanager mentions that the examiner should assert a specific penalty \nnot previously determined by that examiner, that manager needs to \nsecure the written approval of their immediate supervisor. IRC § \n6751(b)(1). \n• Penalty approvals must be timely. See Interim Guidance Memorandum \nSBSE-20-0520-0029 directing examiners when to secure penalty approval \nfor all penalties other than those set forth in IRC §§ 6651, 6654, and 6655 \nand those automatically calculated through electronic means. That \nmemorandum provides: For all penalties subject to section 6751(b)(1), \nwritten supervisory approval required under section 6751(b)(1) must be \nobtained prior to issuing any written communication of penalties to a \ntaxpayer that offers the taxpayer an opportunity to sign an agreement or \nconsent to assessment or proposal of the penalty. \n(4) As a best practice, Examiners should keep detailed notes about supervisory \napproval. The notes should include the following information: \n• who made the initial determination to assert each penalty; \n• when those determinations were made; \n• when those penalties were first approved in writing; \n• who approved those penalties; \n• what the approver’s relationship is to the person who initially determined \nthe penalty (it should always be the determiner’s immediate supervisor); \nand \n• when those penalties were first communicated to the taxpayer. \n(5) Noting this information will help Counsel defend penalties and may limit the \ntimes examiners have to testify about the matter. \n(6) Retain all penalty approvals in your file. If you later determine a penalty does \nnot apply or the amount of the penalty changes, do not destroy the previous \n", "117 \n \napproval. You should note the change in determination or amount while making \nsure to retain the previous approval. \n(7) Examiners should consult Counsel with any IRC § 6751(b) questions. \nC. Accuracy-Related Penalties \n(1) Section 6662 imposes accuracy-related penalties on underpayments. \nGenerally, the accuracy- related penalty imposed on any portion of an \nunderpayment is 20% (40% in the case of a gross valuation misstatement \nunder IRC6662(h) and nondisclosed noneconomic substance transaction under \nIRC § 6662(i)), even if that portion of the underpayment is attributable to more \nthan one type of misconduct. In every case, Examiners should consider all the \nfacts and circumstances to determine if a penalty, an any alternative bases for \nthe penalty, apply. \n(2) The most common accuracy-related penalties in conservation easement cases \nwill be for IRC § 6662(h) gross valuation misstatements, IRC § 6662(b)(1) \nnegligence or disregard of rules or regulations, IRC § 6662(b)(2) substantial \nunderstatements of income tax, and IRC § 6662(b)(3) substantial valuation \nmisstatements. Often, an examiner will find it appropriate to assert the IRC § \n6662(h) gross valuation misstatement as a primary theory and to assert the \nthree penalties listed in IRC §§ 6662(b)(1)-(3) in the alternative. In syndicated \nconservation easement cases, Examiners may also assert IRC § 6662A. \nC.1. Section 6662(b)(1) and (c) Negligence or Disregard of Rules or \nRegulations \n(1) A 20% accuracy-related penalty should be asserted pursuant to IRC § \n6662(b)(1) and (c) if the underpayment of tax is attributable to negligence or to \na careless, reckless, or intentional disregard of rules or regulations. \n(2) Negligence includes any failure to make a reasonable attempt to comply with \nthe provisions of the Internal Revenue Code or to exercise ordinary and \nreasonable care in the preparation of a tax return. IRC § 6662(c); Treas. Reg. § \n1.6662-3(b). \n(3) In Turner v. Commissioner, 126 T.C. 299 (2006), the tax court held that the \ntaxpayer was liable for a 20% negligence penalty under IRC § 6662(c). In that \ncase, the appraiser's report was not considered sufficient for the IRC § 6664(c) \nreasonable cause exception to apply because the report was based on \nerroneous assumptions. \n(4) The term “disregard” includes any careless, reckless, or intentional disregard of \nrules or regulations. A disregard is careless if the taxpayer does not exercise \nreasonable diligence to determine the correctness of a return position that is \ncontrary to a rule or regulation. A disregard is reckless where the taxpayer \nmakes little or no effort to determine whether a rule or regulation exists, under \ncircumstances which demonstrate a substantial deviation from the standard of \n", "118 \n \nconduct that a reasonable person would observe. Disregard is intentional where \nthe taxpayer has knowledge of the rule or regulation that the taxpayer \ndisregards. Treas. Reg. § 1.6662-3(b)(2). \n(5) The terms “rules or regulations” under this section includes the provisions of the \nIRC, temporary or final Treasury regulations, and revenue rulings or notices \n(other than notices of proposed rulemaking) issued by the Internal Revenue \nService and published in the Internal Revenue Bulletin. Treas. Reg. § 1.6662-\n3(b)(2). Therefore, if the facts indicate that a taxpayer took a return position \ncontrary to any published notice or revenue ruling, the taxpayer may be subject \nto the accuracy-related penalty for an underpayment attributable to disregard of \nrules or regulations. \n(6) See IRM 20.1.5.7, Negligence or Disregard of Rules or Regulations for \nadditional guidance. \nC.2. Section 6662(b)(2) and (d) Substantial Understatement of Income \nTax \n(1) A 20% accuracy-related penalty should be asserted pursuant to IRC § \n6662(b)(2) and (d) if the underpayment of tax is attributable to a substantial \nunderstatement of income tax. \n(2) A substantial understatement of income tax exists for a taxable year of an \nindividual if the amount of understatement exceeds the greater of 10% of the \ntax required to be shown on the return or $5,000. IRC § 6662(d)(1)(A). \n(3) An understatement of income tax of a corporation (other than an S Corporation \nor a personal holding company) is substantial if it exceeds the lesser of 10% of \nthe tax required to be shown on the return (or, if greater, $10,000), or \n$10,000,000. IRC § 6662(d)(1)(B). \n(4) The amount of the understatement generally is reduced by the portion of the \nunderstatement attributable to any item if: \n• The treatment is, or was, supported by substantial authority, or \n• Facts relevant to the tax treatment were adequately disclosed on the \nreturn or on a statement attached to the return and there is a reasonable \nbasis for the tax treatment. \n(5) IRC § 6662(d)(2)(B). \n(6) There is no reduction, however, for any item attributable to a tax shelter, which \nmeans either: (1) a partnership or other entity, (2) any investment plan or \narrangement, or (3) any other plan or arrangement, if a significant purpose of \nsuch partnership, entity, plan, or arrangement is the avoidance or evasion of \nfederal income tax. IRC § 6662(d)(2)(C). \n(7) See IRM 20.1.5.9, Substantial Understatement, for additional guidance. \nC.3. Section 6662(b)(3) and (e) Substantial Valuation Misstatement \n", "119 \n \nand Section 6662(h) Gross Valuation Misstatement \n(1) A 20% accuracy-related penalty can be asserted pursuant to IRC § 6662(b)(3) \nand (e) if the underpayment of tax is attributable to a substantial valuation \nmisstatement. IRC § 6662(e)(1). \n(2) A 40% accuracy-related penalty can be asserted pursuant to IRC § 6662(h) if \nthe underpayment of income tax is attributable to a gross valuation \nmisstatement. \n(3) A substantial valuation misstatement exists when the claimed value of any \nproperty is 150% or more of the amount determined to be the correct value. A \ngross valuation misstatement occurs when the claimed value of any property is \n200% or more of the amount determined to be the correct value. \n(4) Note: The Pension Protection Act of 2006 (PPA), Pub. L. No. 109–280, sec. \n1219(a)(2)(B), 120 Stat. at 1083, amended the rules for the 40% gross \nvaluation misstatement penalty. Before the PPA, the penalty applied when \ntaxpayers misstated the value of their property by 400% or more, and taxpayers \ncould avoid the penalty under certain circumstances if they made the \nmisstatement in good faith and with reasonable cause. The IRC § 6664(c) \nreasonable cause exception applied to both substantial and gross valuation \nmisstatements. The PPA lowered the threshold for gross valuation \nmisstatements to 200% and eliminated the reasonable cause exception for \ngross valuation misstatements of charitable contribution property. See secs. \n6662(h), 6664(c). \n(5) No penalty is imposed unless the portion of the underpayment attributable to \nthe valuation misstatement exceeds $5,000 ($10,000 in the case of a \ncorporation other than an S corporation or a personal holding company). IRC § \n6662(e)(2). \n(6) See IRM 20.1.5.10, Substantial Valuation Misstatement and IRM 20.1.5.10.3, \nIRC 6662(h) Gross Valuation Misstatement, for additional guidance. \nC.4. Section 6662(b)(6) and (i) Codified Economic Substance \nDoctrine \n(1) Section 6662(b)(6) provides for a 20% penalty in the case of an underpayment \nattributable to any disallowance of claimed tax benefits by reason of a \ntransaction lacking economic substance (within the meaning of IRC § 7701(o)) \nor failing to meet the requirements of any similar rule of law. See Chapter 10 for \nmore information relating to IRC § 7701(o). \n(2) Section 6662(i)(1) provides that the penalty shall be imposed at the rate of 40% \nin the case of a nondisclosed noneconomic substance transaction as defined in \nIRC § 6662(i)(2). The term “nondisclosed noneconomic substance transaction” \nmeans any portion of a transaction described in IRC § 6662(b)(6) with respect \n", "120 \n \nto which the relevant facts affecting the tax treatment are not adequately \ndisclosed in the return nor in a statement attached to the return. \nD. Section 6663 Civil Fraud Penalty \n(1) Section 6663 imposes a penalty of 75% on any portion of the underpayment of \ntax is due to fraud. \n(2) In a TEFRA partnership matter, the IRS must prove, by clear and convincing \nevidence, the partnership-level elements of the fraud penalty based on the \nconduct and intent of the managing partner(s). If the IRS proves fraud, the \nfraud penalty is applicable to all the partners in the partnership on any \nunderpayments of tax resulting from the adjustments to partnership items that \nare attributable to fraud. Those partners may then raise any partner-level \ndefenses in refund actions under section 6230(c). \n(3) Examiners should be alert to any indications of fraud, which can be \ndemonstrated through a pattern of conduct. See CC Notice 2020-008, Question \nand Answer 2. The Office of Fraud Enforcement and Counsel can assist \nExaminers as necessary. If badges of fraud are noted, Examiners are required \nto discuss this with their group manager and involve the local fraud technical \nadvisors as early as possible. \n(4) See IRM 20.1.5.16, Civil Fraud Penalty, for additional guidance. \nE. Section 6664 Reasonable Cause Exception \n(1) In general, no penalty will be asserted under IRC §§ 6662 or 6663 if the \ntaxpayer establishes there was reasonable cause for the underpayment and the \ntaxpayer acted in good faith. IRC § 6664(c)(1). See IRM 20.1.5.7.1 & \n20.1.5.10.7.1, Reasonable Cause, for additional guidance. \n(2) Reasonable cause must be determined on a case-by-case basis, taking into \naccount all the pertinent facts and circumstances. To determine whether \nreasonable cause exists, examiners must ascertain the taxpayer’s experience, \nknowledge, education, the extent of the taxpayer’s review or inquiry in \nassessing the correctness of the conservation easement donation, and whether \nthe taxpayer relied on any appraisers, return preparers, or other professionals. \nE.1. Special Rule for Overvaluation of Charitable Contributions \n(1) For substantial valuation misstatements of charitable contribution property, \nreasonable cause may apply only if: \n• The claimed value of the property was based on a qualified appraisal \nmade by a qualified appraiser, and \n• In addition to obtaining the appraisal, the taxpayer made a good faith \ninvestigation of the value of the contributed property. \n(2) IRC § 6664(c)(3). \n", "121 \n \n(3) Improper valuation of conservation easements and a lack of a qualified \nappraisal are common bases for full or partial disallowance of the charitable \ncontribution deduction. Accordingly, if the easement is substantially overvalued \n(150% or more), the reasonable cause exception cannot apply unless the \nappraisal was a qualified appraisal by a qualified appraiser and the taxpayer \nmade a good faith investigation of the value of the easement in addition to \nsecuring the appraisal. \n(4) For returns filed after July 25, 2006, the reasonable cause exception is not \navailable for gross valuation misstatements. IRC § 6664(c)(3). \nE.2. Reliance on Professionals \n(1) Reliance on a return preparer or other professional such as an attorney or \nappraiser does not automatically constitute reasonable cause and good faith \nunder Treas. Reg. § 1.6664-4(b). Curtis Investment Company, LLC v. \nCommissioner, T.C. Memo. 2017-150, at 7-9, 40-46 (holding no reasonable \ncause even through the taxpayers claimed they relied on three tax \nprofessionals who reviewed the underlying transaction because the tax \nprofessionals relied solely on the opinion letter obtained by the promoter and \ndid not provide their own opinion letters). \n(2) Reliance constitutes reasonable cause and good faith if, under all the \ncircumstances, such reliance was reasonable and the taxpayer acted in good \nfaith. However, reasonable cause relief is not appropriate if the professional \nrelief upon was the promoter of the transaction. CNT Investors, LLC v. \nCommissioner, 144 T.C. 161, 226 (2015). \n(3) Reasonable cause and good faith may exist if the taxpayers can demonstrate \nthat: \n• They did not know, nor should have known, that the advisor suffered from \na conflict of interest or a lack of expertise, \n• Complete, accurate and all necessary information was provided to the \nadvisor by the taxpayers, and \n• The taxpayers actually relied in good faith on the advisor’s judgment. \n(4) CNT Investors, LLC v. Commissioner, 144 T.C. 161, 223 (2015). \n(5) If the taxpayer claims reliance on professionals, the examiner must identify \nspecifically who advised the taxpayer and when and what services or advice \nwere provided and determine whether the taxpayer fully disclosed the \nnecessary information for the advisor to make a proper determination. \n(6) This will generally require an interview of the taxpayer and of the professional to \nconfirm the taxpayer's information and evaluate whether non-assertion of the \npenalty is appropriate due to reasonable cause. Copies of any professional \nopinion letters, correspondence, analysis, billing records or other \n", "122 \n \ndocumentation should be solicited from the taxpayer or professional to \nsubstantiate reliance on professionals. \n(7) Examiners should review IRM 20.1.5.7.4, Reliance on Advice, for additional \nguidance. \nF. Section 6694 Understatement of Taxpayer’s Liability by Tax Return \nPreparer \n(1) Examiners are responsible for determining whether IRC § 6694 penalties \nshould be asserted on the return preparer. Preparer penalties should be \nasserted only after consideration of all facts and circumstances and not based \nsolely on the determination of deficiencies in related tax return examinations. \n(2) Examiners may consider asserting penalties under IRC § 6694 on appraisers \nfor inflated or incorrect appraisals in lieu of IRC § 6695A if the appraiser meets \nthe definition of a nonsigning return preparer. Treas. Reg. § 301.7701-15(b)(2). \n(3) CAUTION: The statute of limitations on assessing the IRC § 6694(a) penalty is \nthree years from the date the return or claim for refund (from which the penalty \nstems) was filed. IRC § 6696(d). Securing an extension on the return being \nexamined does not extend the IRC § 6694(a) penalty statute. Form 872-D, \nConsent to Extend the Time on Assessment of Tax Return Preparer Penalty is \nused to extend the IRC § 6694(a) case statute. \n(4) There is no statute of limitations on assessment of the IRC § 6694(b) penalty. \nIRC § 6696(d). However, in the interest of efficiency and preserving evidence, \nthese examinations should not be delayed. \n(5) IRM 20.1.6, Preparer, Promoter, Material Advisor Penalties, provides additional \nguidance on the return preparer penalties. Examiners also may contact their \nlocal Return Preparer Coordinator for help with preparer penalty cases. \nG. Sections 6700 and 6701 Penalty for Promoting Abusive Tax \nShelters and Aiding and Abetting Understatements of Tax \n(1) Various individuals (or entities) may be subject to penalty under IRC §§ 6700 or \n6701 for their role in the transaction. For example, appraisers may be subject to \nIRC § 6700 for direct or indirect participation in the sale of a tax plan or \narrangement that results in a material gross overvaluation misstatement. \nSection 6701 penalties may also be applicable for the preparation of the \nappraisal if the appraiser knows or had reason to believe that the appraisal was \nto be used in connection with a material tax matter and knows that use of the \ndocument would result in an understatement of tax. \n(2) The examiner should consider a referral to the SB/SE Lead Development \nCenter (LDC) for return preparers, appraisers, promoters, authors of legal \nopinions, donee organizations, or anyone else who was directly or indirectly \n", "123 \n \ninvolved with a scheme or promotion advocating improper or overvalued \nconservation easement donations. \n(3) While examiners may secure information on the role and level of involvement of \neach person in conjunction with the determination of the appropriateness of \ntaxpayer penalties, examiners cannot commence an IRC § 6700, Promoting \nAbusive Tax Shelters, Etc., or IRC § 6701, Aiding and Abetting Understatement \nof Tax Liability, penalty investigation without specific authorization from the \nSB/SE LDC. A referral form can be found on the LDC Web page. \n(4) Contact a SB/SE LDC program analyst for assistance on the application of IRC \n§ 6700 or 6701 penalties, determination of whether a referral is warranted, or \ncoordination of participant examinations. \n(5) There is no statute of limitations on asserting the IRC §§ 6700 and 6701 \npenalties. However, in the interest of efficiency and preserving evidence, these \nexaminations should not be delayed. \n(6) See IRM 20.1.6, Overview of the Return Preparer, Promoter, and Material \nAdvisor Penalties, and IRM 4.32 for additional guidance. \nH. Section 6695A Substantial and Gross Valuation Misstatements \nAttributable to Incorrect Appraisals \n(1) Section 6695A was added by the Pension Protection Act of 2006. It provides a \ncivil penalty on any person who prepares an appraisal of the value of property \nthat the appraiser knows (or reasonably should have known) is to be used in \nconnection with a return or a claim for refund, and such appraisal results in a \nsubstantial or gross valuation misstatement (as defined in IRC § 6662(e) and \n(h) respectively). \n(2) The amount of the IRC § 6695A penalty is the lesser of: \n• The greater of 10% of the amount of the underpayment attributable to the \nmisstatement or $1,000, or \n• 125% of the gross income received from the preparation of the appraisal \n(3) Under IRC § 6695A(c), the penalty does not apply if the appraiser establishes \nthat it was \"more likely than not\" that the value established in the appraisal was \ncorrect. \n(4) There are no preassessment appeal rights extended to the appraiser at the time \nof the penalty case closure by the examiner. The appraiser may request an \nappeals conference upon notice of the Service’s intent to assess the penalty. \n(5) CAUTION: The statute of limitations for the appraiser penalty case is three \nyears from the later of the due date of the related return or the date the return \nwas filed. Securing an extension on the return being examined does not extend \nthe appraiser penalty statute. Form 872-AP, Consent to Extend the Time on \n", "124 \n \nAssessment of IRC Section 6695A Penalty, is used to extend the appraiser \npenalty case statute. \n(6) Interim guidance on how to open and pursue an IRC § 6695A case was issued \non January 22, 2020 at LB&I-20-0120-001. Please review that document when \nyou believe an IRC § 6695A penalty case should be opened. \n(7) See IRM 20.1.12, Penalties Applicable to Incorrect Appraisals, and the \nServicewide Penalty Web page for additional guidance on the assessment of \nthis penalty. \nH.1. Office of Professional Responsibility Sanctions \n(1) Prior to the changes instituted by the Pension Protection Act of 2006 (PPA), an \nIRC § 6701 penalty for aiding and abetting was required to be assessed before \nthe Office of Professional Responsibility (OPR) could seek disciplinary action \nagainst an appraiser. \n(2) The PPA eliminated the penalty assessment requirement. Disciplinary action \nmay include, but is not limited to, suspending or barring an appraiser from: \n• Preparing or presenting appraisals on the value of property or other assets \nto the Treasury Department or the IRS. \n• Appearing before the Treasury Department or the IRS for the purpose of \noffering opinion evidence on the value of property or assets. \nI. Penalties Specifically Related to Reportable Transactions \n(1) Certain penalties are applicable only to reportable transactions as defined in \nTreas. Reg. § 1.6011-4(b). In Notice 2017-10, the IRS identified certain \nsyndicated conservation easement transactions as listed transactions. A \nsyndicated conservation easement transaction is a listed transaction if: \n• An investor receives promotional materials that offer prospective investors \nin a pass-through entity the possibility of a charitable contribution \ndeduction that equals or exceeds an amount that is two and one-half times \nthe amount of the investor’s investment. \n• The promotional materials may be oral or written. \n• For purposes of this notice, promotional materials include, but are \nnot limited to, documents described in § 301.6112-1(b)(3)(iii)(B) of \nthe Regulations. \n• The investor purchases an interest, directly or indirectly (through one or \nmore tiers of pass-through entities), in the pass-through entity that holds \nreal property. \n• The pass-through entity that holds the real property contributes a \nconservation easement encumbering the property to a tax-exempt entity \n", "125 \n \nand allocates, directly or through one or more tiers of pass-through \nentities, a charitable contribution deduction to the investor. \n• Following that contribution, the investor reports on his or her federal \nincome tax return a charitable contribution deduction with respect to the \nconservation easement. \n(2) Transactions that are the same or similar to the transaction described above \nare considered listed transactions. \n(3) If a syndicated conservation easement transaction was entered into by a \ntaxpayer on or after January 1, 2010, the taxpayer must have reported their \nparticipation. Similarly, material advisors have similar obligations to disclose \ntheir participation in listed transactions. IRC § 6111. A material advisor is any \nperson: \n• who provides any material aid, assistance, or advice with respect to \norganizing, managing, promoting, selling, implementing, insuring, or \ncarrying out any reportable or listed transaction, and \n• who directly or indirectly derives gross income in excess of $250,000 \n($50,000 for a reportable or listed transaction if substantially all of the tax \nbenefits of the transactions are provided to natural persons). \n(4) IRC § 6111(b)(1)(B). \nI.1. Section 6662A Accuracy-Related Penalty on Understatements with \nRespect to Reportable Transactions \n(1) Section 6662A sets forth a special accuracy-related penalty for \nunderstatements resulting from reportable transactions. A reportable \ntransaction understatement is not calculated in the same manner as the \naccuracy-related penalty under IRC § 6662. An example of how to calculate this \namount can be found at IRM 20.1.5.17.2. \n(2) The IRC § 6662A accuracy-related penalty is 20% of the reportable transaction \nunderstatement if the transaction is property disclosed and 30% if the \ntransaction is not property disclosed. IRC § 6662A(c). \n(3) In determining whether reasonable cause should excuse the IRC § 6662A \npenalty, an examiner should look to the special definition of reasonable cause \nspecifically set out for that penalty which is described in IRC § 6664(d). To \nreceive reasonable cause relief, the taxpayer must have shown not only \nreasonable cause (as discussed for the accuracy-related penalties), but also \nthat the taxpayer: \n• Adequately disclosed the relevant facts about the transaction; \n• Had substantial authority for claiming the tax treatment of the transaction, \nand \n• Believed the treatment was more likely than not correct. IRC § 6664(d)(3). \n", "126 \n \nI.2. Section 6707A Penalty for Failure to Include Reportable \nTransaction Information with Return \n(1) Section 6707A(a) provides that any person who fails to file a timely, complete \nForm 8886, Reportable Transaction Disclosure Statement, is subject to a \npenalty. The IRC § 6707A penalty is imposed in addition to any other penalty. \nThere is no reasonable cause exception to the § 6707A penalty. Generally, the \nCommissioner may rescind the penalty if doing so would promote compliance \nwith the IRC and effective tax administration. Treas. Reg. § 301.6707A-\n1(e)(1)(i). This rule does not apply to listed transactions and so is unavailable \nin the case of a transaction described in Notice 2017-10, Section 2, and \nsubstantially similar transactions. \n(2) For listed SCE transactions described in Notice 2017-10, “participants” include \n(but are not limited to) investors, the pass-through entity (any tier, if multiple \ntiers are involved), or any other person whose tax return reflects the tax \nconsequences of such SCE transaction. The Notice specifically provides that a \ndonee described in § 170(c) shall not be treated as a participant in the SCE \ntransaction under § 1.6011-4. \n(3) Under § 6707A(b)(1), the amount of the penalty is 75% of the decrease in tax \nshown on the return as a result of the listed transaction, or the decrease that \nwould have resulted from the transaction if it were respected for federal tax \npurposes. The penalty amount is subject to the maximum and minimum \namounts. The maximum penalty under § 6707A(b)(2)(A) for listed transactions \nis $200,000 ($100,000 in the case of a natural person), and the minimum \npenalty under § 6707A(b)(3) is $10,000 ($5,000 in the case of a natural \nperson). \n(4) A penalty imposed under § 6707A is in addition to any other penalty imposed \nunder the Internal Revenue Code. § 6707A(f); Treas. Reg. § 301.6707A-1(a); \nIRM 4.32.4.1.1(3). \nI.3. Section 6707 Failure to Furnish Information Regarding Reportable \nTransaction \n(1) Section 6707(a) provides that any material advisor who fails to file a timely, \ncomplete Form 8918, Material Advisor Disclosure Statement, is subject to a \npenalty. There is no reasonable cause exception to the § 6707 penalty. \nGenerally, the Commissioner may rescind the penalty if doing so would \npromote compliance with the IRC and effective tax administration. IRC § \n6707(c). This rule does not apply to listed transactions and so is unavailable in \nthe case of a transaction described in Notice 2017-10, Section 2, and \nsubstantially similar transactions. \n(2) The penalty amount equals $50,000 for any failure. In the case of listed \ntransactions, including transactions described in Notice 2017-10, Section 2, and \nsubstantially similar transactions, the penalty is the greater of $200,000 or 50 % \n", "127 \n \nof the gross income derived by such person with respect to aid, assistance, or \nadvice which is provided with respect to the listed transaction before the date \nthe return is filed under section 6111. In the case of an intentional failure the \npenalty is the greater of $200,000 or 75% of the gross income derived by such \nperson with respect to aid, assistance, or advice which is provided with respect \nto the listed transaction before the date the return is filed under section 6111. \nI.4. Section 6708 Failure to Maintain Lists of Advisees with Respect to \nReportable Transactions \n(1) Section 6708 provides a penalty applicable to a material advisor who does not \nmake a list required to be maintain under IRC 6112 available to the Service \nwithin 20 business days of a request. For more information about making such \na request, see IRM 4.32.2.8.2.2.2, Issuance of IRC 6112 Letter. The penalty \ncan be imposed in addition to any other penalty. The penalty is subject to a \nreasonable cause exception. \n(2) The amount of the penalty is $10,000 per day. \nXV. State Tax Credits \nA. Overview \n(1) An increasing number of states offer incentives in the form of income tax credits \nfor the donation of conservation easements. Some state conservation \neasement tax credit programs allow for the transfer and sale of the tax credits. \nA taxpayer may qualify for a state tax credit, but still not qualify for a federal tax \ndeduction. \nB. State Tax Credit Programs \n(1) The following states and territories have or had some form of tax credit \nprograms for conservation easements: \n• Arkansas (a “wetland and riparian zone conservation tax credit”) \n• California \n• Colorado \n• Connecticut \n• Delaware \n• Florida (exemption from real property tax) \n• Georgia \n• Iowa \n• Maryland \n• Massachusetts \n", "128 \n \n• Mississippi \n• New Mexico \n• New York \n• North Carolina (repealed for tax years after 2013) \n• South Carolina \n• Virginia \n• Wisconsin (limited to farmland preservation agreements, and the farmland \nmust be in a farmland preservation area identified in a certified farmland \npreservation plan) \n• Puerto Rico \n(2) The requirements for most state tax credit programs are similar to the \nrequirements under IRC § 170(h) for deducting the contribution of a \nconservation easement. There is no uniform model, but most state programs \ndetermine the amount of the credit based on a percentage of the FMV of the \ndonated easement. Generally, the programs provide for carryforward of unused \ntax credits over a number of years. Some states, including Colorado, South \nCarolina, Virginia, New Mexico, and Georgia have transferable tax credits. \nPuerto Rico also has transferable tax credits available only to the original donor \nof the easement. \n(3) Transferability allows taxpayers to sell tax credits to third parties. Credit brokers \nor facilitators assist taxpayers in negotiating the sales price and are generally \nreimbursed for their services from the proceeds of the sale. The tax credit \npurchasers then use the credits to pay their own state tax liabilities. \n(4) In 2007, The Conservation Resource Center, a nonprofit conservation \norganization, published a report analyzing the impact of state conservation tax \ncredits. According to the report, taxpayers generally receive as much as 70 to \n82 percent of the face value of their state tax credits, depending on market \nrates at the time of the sale. \nC. Receipt of State Tax Credits \n(1) Generally, a state tax credit, to the extent that it can be applied against the \noriginal recipient's current or future state tax liability, is treated for federal \nincome tax purposes as a reduction or potential reduction in that taxpayer’s \nstate tax liability, not as a payment of cash or property to the taxpayer that is \nincludible in gross income under IRC § 61. See generally Maines v. \nCommissioner, 144 T.C. 123, 143 (2015). \n(2) For an easement donated on or before August 27, 2018, the receipt of a state \nconservation easement tax credit does not reduce the amount of the taxpayer’s \nfederal charitable contribution deduction under IRC § 170. See Tempel v. \nCommissioner, 134 T.C. 341, 351 n.17 (2011), aff’d sub nom, Esgar Corp. v. \n", "129 \n \nCommissioner, 744 F.3d 648 (10th Cir. 2014). For those donations, the federal \ntax effect to the original recipient of a state credit is normally a reduction in the \namount of state tax imposed and paid for purposes of IRC § 164. The mere fact \nthe state tax credit is transferable does not cause it to lose its character as a \nreduction or potential reduction in liability in the hands of the taxpayer who \noriginally qualified for the credit. If the state tax credit is sold or exchanged, \nplease contact Counsel for advice on the federal tax treatment of the credit. \n(3) Donations of conservation easements made after August 27, 2018, that result in \na state tax credit reduce the amount of the taxpayer’s federal charitable \ncontribution deduction under IRC § 170. Treas. Reg. § 1.170A-1(h)(3). Most \nstate credits received for donations of conservation easements made after \nAugust 27, 2018, are considered quid pro quo benefits by the regulations. \nTreas. Reg. § 1.170A-1(h)(3). As a result, the deductions for these contributions \nmust be reduced by the amount of the state tax credit. Treas. Reg. § 1.170A-\n1(h)(3)(i). However, if the total amount of the state and local tax credits is 15% \nor less of the taxpayer’s payment, or 15% or less of the FMV of the property \ntransferred by the taxpayer, then the state tax credit is not considered a quid \npro quo benefit and will not reduce the allowable deduction. Treas. Reg. § \n1.170A-1(h)(3)(vi). \n(4) While state tax credits reduce the amount of the allowable federal tax \ndeduction, state tax deductions do not reduce the allowed federal tax deduction \n(unless the state tax deduction exceeds the amount of the taxpayer’s payment \nor the FMV of the property contributed). Treas. Reg. § 1.170A-1(h)(3)(ii). \nD. Sale of State Tax Credits \n(1) Please contact Counsel if it is determined that during a year at issue a taxpayer \nsold any state tax credits related to a conservation easement. \n \n" ]
i1118sj.pdf	1220 Inst 1118 (Schedule J) (PDF)	https://www.irs.gov/pub/irs-pdf/i1118sj.pdf	[ "Instructions for Schedule J \n(Form 1118)\n(Rev. December 2020)\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue \nCode unless otherwise noted.\nFuture Developments\nFor the latest information about \ndevelopments related to Schedule J \n(Form 1118) and instructions, such as \nlegislation enacted after they were \npublished, go to IRS.gov/Form1118.\nWhat’s New\nOn Schedule J (Form 1118), the column \nheadings and lines used to report \"other \nincome\" have been revised to require \ntaxpayers to identify each item of other \nincome. In these instructions, the \nComputer-Generated Schedule section, \nbelow, has been revised to indicate how \neach item of other income is to be \nidentified.\nGeneral Instructions\nPurpose of Schedule\n• Use Part I to show adjustments to \nseparate limitation income or (losses) in \ndetermining the numerator of the limitation \nfraction for each separate category.\n• Use Part II to show the year-end \nbalances of future separate limitation \nincome that must be recharacterized as \nincome in other separate categories (as \nthe result of current year or prior year \nseparate limitation losses that were \nallocated to reduce income in those other \nseparate categories).\n• Use Part III to show: (a) the balances in \nthe corporation's overall foreign loss \naccounts at the beginning of the tax year, \n(b) any current year adjustments, and (c) \nthe balances in the overall foreign loss \naccounts at the end of the tax year.\n• Use Part IV to show: (a) the balances in \nthe corporation's overall domestic loss \naccounts at the beginning of the tax year, \n(b) any current year adjustments, and (c) \nthe balances in the overall domestic loss \naccounts at the end of the tax year.\nImportant. Complete Schedule J only \nonce. Include adjustments for each \napplicable separate category. \nComputer-Generated Schedule\nA computer-generated Schedule J can be \nfiled if it conforms to the IRS version of the \nschedule.\nIf the corporation has more than \none separate category of \"other \nincome,\" expand Schedule J as \nexplained below to properly complete \nParts I, II, III, and IV of the schedule.\nA corporation has more than one \nseparate category of \"other income\" if it \nhas more than one of the following:\n• Income from a sanctioned country to \nwhich section 901(j) applies (each \nsanctioned country is a separate category \nof income).\n• An item of income resourced under a \ntax treaty (see Regulations section \n1.904-4(k) for rules regarding grouping of \nitems of treaty resourced income into \nseparate categories).\nIf the corporation has more than one \nseparate category of “other income,” add \na column (and, in some cases, a line, if \ncompleting Part l, line 2; Part I, line 9; \nand/or Part II) for each additional separate \ncategory of other income. Each column \nand line must be identified as follows. With \nrespect to the 901(j) category of income, \nthe category must be identified as “901(j) -\nname of sanctioned country.” With respect \nto the resourced by treaty category of \nincome, the category must be identified as \n“RBT - name of treaty country and \nseparate category of items of income. For \nexample, if you are filing a Form 1118 for \nseparate category code RBT-PAS with \nrespect to treaty Country X, you would \nenter “RBT - Country X, Passive.” \nFurthermore, for each new line, the \namounts going across the line must equal \nzero.\nSpecific Instructions\nPart I\nNote. See Regulations section 1.904(g)-3 \nfor detailed information on the ordering of \nadjustments in Part I.\nLine 1. For columns (i) through (v), enter \nin each applicable column, the income or \n(loss) from column 18 of the \ncorresponding Schedule A for that \nseparate category. In column (vi), enter an \namount equal to the income or (loss) from \nSchedule B, Part II, line 8c, minus the \naggregate income or (loss) entered in the \nother columns of this line 1.\nLine 2. This allocation grid must be \ncompleted to show the pro rata share of \neach separate limitation loss to allocate \nCAUTION\n!\namong other applicable separate \ncategories.\nTo determine each pro rata share:\n1.\nAdd all of the separate limitation \nloss amounts entered across line 1. Then \nadd all of the separate limitation income \namounts entered across line 1.\n2.\nIf the combined separate limitation \nlosses for the tax year do not exceed the \ncombined separate limitation income for \nthe tax year, the pro rata share of each \nseparate limitation loss to allocate to each \ncategory with positive income is as \nfollows:\n(Separate limitation income / \nCombined separate limitation income from \nall categories with positive income) x \nSeparate limitation loss being allocated\n3.\nIf the combined separate limitation \nlosses for the tax year exceed the \ncombined separate limitation income for \nthe tax year, the pro rata share of each \nseparate limitation loss to allocate to each \ncategory with positive income is as \nfollows:\n(Separate limitation loss being \nallocated / Combined separate limitation \nlosses from all categories with losses) x \nSeparate limitation income in a given \ncategory\nIf separate limitation losses can be \nallocated, enter the total amounts \nallocated in the bold-outlined boxes as \npositive numbers. Enter each separate \namount allocated to a given category \nacross the same line under the \nappropriate column heading to which it \nwas allocated.\nNote. The numbers entered across any \ngiven line should equal zero.\nIf a separate limitation loss in one \ncategory offsets income in a second \ncategory and the second category has a \nseparate limitation loss account balance \nthat has not been recaptured with respect \nto the first category, then the two offsetting \nseparate limitation loss account balances \nare netted for purposes of determining the \namount of income in the second category \nthat is subject to recharacterization on \nline 9, Part I, if any, and for purposes of \ndetermining the year-end balances in both \ncategories reported in Part II.\nThe combined separate limitation \nlosses for the tax year that are more than \nthe combined separate limitation income \nfor the tax year reduce the U.S. source \nJan 28, 2021\nCat. No. 50277F\n", "income (if any) for the tax year. If the \ncorporation has no U.S. source income for \nthe tax year, or if the excess of its \ncombined separate limitation losses for \nthe tax year over combined separate \nlimitation income for the tax year exceeds \nits U.S. source income for the tax year, the \nexcess is treated as a net operating loss. \nThis loss may be carried over or back to \nother tax years according to the rules of \nsection 172.\nExample 1. Corporation X has a \nseparate limitation loss of $2,000 in its \ngeneral category (line 1, column (iv)) and \nseparate limitation income of $4,000 in its \npassive category (line 1, column (iii)). In \naddition, the corporation has separate \nlimitation income of $1,000 in its treaty \nresourced general category income \n(line 1, column (v)).\nSince the corporation's combined \nseparate limitation losses for the tax year \n($2,000) do not exceed its combined \nseparate limitation income for the tax year \n($5,000), the entire $2,000 loss may be \nallocated to other separate categories. \nTherefore, Corporation X enters a positive \n$2,000 in the bold-outlined box on line 2d, \ncolumn (iv).\nTo compute the portion of the $2,000 \nseparate limitation loss that is allocable to \npassive category income, Corporation X \ndivides the $4,000 of income by $5,000 \n(the combined separate limitation income \nfrom all separate categories with positive \nincome). The result of 80% is multiplied by \nthe separate limitation loss of $2,000. \nCorporation X enters the product of \n$1,600 on line 2d, column (iii).\nTo compute the portion of the $2,000 \nseparate limitation loss that is allocable to \ntreaty resourced general category income, \nCorporation X divides the $1,000 of \nseparate limitation income by $5,000. The \nresult of 20% is multiplied by the separate \nlimitation loss of $2,000. Corporation X \nenters the product of $400 on line 2d, \ncolumn (v).\nCorporation X enters $0 (negative \n$2,000 plus positive $2,000) on line 3, \ncolumn (iv); $2,400 ($4,000 minus $1,600) \non line 3, column (iii); and $600 ($1,000 \nminus $400) on line 3, column (v).\nLine 4. In columns (i) through (v), enter \nthe overall foreign losses for the tax year \n(from line 3) as positive numbers if they \nhave reduced U.S. source income for the \ntax year. In column (vi), enter the total \namount of overall foreign losses that have \nreduced U.S. source income for the tax \nyear as a negative number.\nNote. The numbers entered across this \nline should equal zero.\nLine 5. In columns (i) through (v), enter \nU.S. source losses allocated to separate \ncategories with income on line 3 for the \ncurrent tax year. In column (vi), enter the \ntotal amount of U.S. losses allocated to \nthe separate categories as a positive \nnumber. Use the following formula:\nU.S. source loss x (Line 3 income in a \ngiven category / Combined line 3 income \nof all separate categories with income on \nline 3)\nU.S. source losses in excess of the \ncombined line 3 income for a tax year is \ntreated as a net operating loss that may be \ncarried back or forward to other tax years \nusing the rules of section 172.\nNote. The numbers entered across this \nline should equal zero.\nLine 7. Recapture overall foreign losses \nthat reduced U.S. source income in prior \ntax years (section 904(f)(1)). To do this, \ntreat a portion of the current year separate \nlimitation income that is of the same \ncategory as the loss that resulted in the \nprior year overall foreign loss as U.S. \nsource income. Recapture continues until \nthe applicable overall foreign loss account \nbalance (Part III) is reduced to zero. Enter \nthe recapture amount for each category of \nseparate limitation income in the \nappropriate column as a negative number. \nEnter the total amount of recapture for all \ncategories of separate limitation income \nas a positive number in column (vi).\nNote. The numbers entered across this \nline should equal zero.\nThe total amount of current year \nseparate limitation income subject to \nrecapture is the smaller of the aggregate \namount of maximum potential recapture in \nall overall foreign loss accounts, or 50% of \nall amounts entered on Part I, line 6, \ncolumns (i) through (v). The maximum \npotential recapture amount for the overall \nforeign loss account in any given category \nis the smaller of the current year separate \nlimitation income in that category (the \napplicable amount entered in Part I, \nline 6), or the balance in the applicable \noverall foreign loss account (the \napplicable line 1 amount in Part III). If the \naggregate amount of maximum potential \nrecapture in all overall foreign loss \naccounts exceeds 50% of all amounts \nentered on Part I, line 6, columns (i) \nthrough (v), then the amount of current \nyear separate limitation income in each \nseparate category subject to recapture is \ncomputed using the following formula:\nTotal recapture amount x (Maximum \npotential recapture amount for the overall \nforeign loss account in the separate \ncategory / Aggregate amount of maximum \npotential recapture in all overall foreign \nloss accounts)\nThe corporation can make an annual, \nrevocable election to recapture a greater \nportion of the balance in an overall foreign \nloss account by attaching a statement to \nForm 1118 indicating:\n1.\nThe percentage and dollar amount \nof the separate limitation income that is \ntreated as U.S. source income, and\n2.\nThe percentage and dollar amount \nof the balance (both before and after \nrecapture) in the overall foreign loss \naccount is recaptured.\nIf the corporation disposes of property \nthat was used predominantly in a foreign \ntrade or business and that generated \nforeign source income in the same \nseparate category as the applicable \noverall foreign loss account, and there is a \nbalance in the account after amounts are \nrecaptured under section 904(f)(1), the \ncorporation may be required to recapture \nan additional amount of the overall foreign \nloss account, whether or not gain would \notherwise be recognized on the \ndisposition. See section 904(f)(3) and \nRegulations section 1.904(f)-2(d) for more \ndetails.\nIf, under these rules, the corporation is \nrequired to recognize gain it would not \nhave otherwise recognized, special \nordering rules apply that impact the steps \nnecessary to complete Schedule J (Form \n1118), including special rules for \ndispositions of property that require \nadditional recognition of income under \nbranch loss recapture and dual \nconsolidated loss recapture rules. See \nRegulations sections 1.904(f)-2(d)(4) and \n1.904(g)-3(i) and (j).\nNote. For dispositions after October 22, \n2004, the previous paragraph applies to \ncertain dispositions of stock in a controlled \nforeign corporation (CFC). See section \n904(f)(3)(D) for details.\nExample 2. Corporation Y has $1,400 \nof current year separate limitation income, \n$1,000 in its general category (Part I, \nline 6, column (iv)) and $400 in its passive \ncategory (Part I, line 6, column (iii)). The \ncorporation has overall foreign loss \naccounts of $600 in its general category \nand $800 in its passive category (Part III, \nline 1, columns (iv) and (iii)). The \nmaximum potential recapture for the \noverall foreign loss account in the general \ncategory is $600 (the smaller of current \nyear income of $1,000 in that category or \nthe overall foreign loss account balance of \n$600). The maximum potential recapture \nfor the overall foreign loss account in the \npassive category is $400 (the smaller of \ncurrent year income of $400 in that \ncategory or the overall foreign loss \naccount balance of $800). The aggregate \namount of maximum potential recapture in \nall overall foreign loss accounts is \ntherefore $1,000 ($600 + $400).\nThe total amount of current year \nincome subject to recharacterization is \n$700 (the smaller of the aggregate amount \n-2-\nInstructions for Schedule J (Form 1118) (Rev. Dec. 2020)\n", "of maximum potential recapture, $1,000, \nor 50% of total current year separate \nlimitation income entered on line 6, Part I \n(50% x $1,400, or $700)). To compute the \namount of current year separate limitation \nincome in the general category that is \ntreated as U.S. source income, \nCorporation Y multiplies the total \nrecapture amount of $700 by the \nmaximum recapture amount for the \ngeneral category of $600, divided by the \naggregate amount of maximum potential \nrecapture of $1,000. Corporation Y enters \nthe result of $420 on line 7, column (iv). To \ncompute the amount of current year \nseparate limitation income in the passive \ncategory that is treated as U.S. source \nincome, Corporation Y multiplies the total \nrecapture amount of $700 by the \nmaximum recapture amount for the \npassive category of $400, divided by the \naggregate amount of maximum potential \nrecapture of $1,000. Corporation Y enters \nthe result of $280 on line 7, column (iii). \nCorporation Y enters the total recapture \namount of $700 as a positive number on \nline 7, column (vi). Note that the total \namounts entered across line 7 equal zero.\nLine 9. If a separate limitation loss was \nallocated in a prior tax year and the \ncorporation has income during the current \ntax year in the separate category from \nwhich the loss was allocated, that current \nyear income (if it was not previously \nrecharacterized) must be recharacterized \nas income of the separate category(ies) to \nwhich the loss was allocated in the prior \nyear(s) (section 904(f)(5)).\nNote. The amount of current year income \nin a category subject to recharacterization \nis limited to the year-end balance in Part II \nfor that category as reported on the prior \ntax year Schedule J, reduced by any \nnetting of offsetting separate limitation \nloss accounts as provided for in the \ninstructions for Part I, line 2.\nIf a prior year separate limitation loss \nwas allocated to more than one separate \ncategory and there is not enough current \nyear income in the separate category from \nwhich the loss was allocated to \nrecharacterize all remaining balances, \nthen the current year income must be \nrecharacterized as income of the other \nseparate categories on a pro rata basis in \nthe following manner:\nCurrent year income in separate \ncategory from which losses were \npreviously allocated x (Amount remaining \nto be recharacterized as income of a given \nseparate category / Amounts remaining to \nbe recharacterized as income of all \nseparate categories)\nAny amount that is not recharacterized \nduring the tax year (i.e., the excess of \nseparate limitation losses previously \nallocated over current year income in that \nsame separate category) must be entered \ninto the grid in Part II.\nNote. Recharacterization of separate \nlimitation income does not result in \nrecharacterizing any tax. The rules of \nRegulations section 1.904-6 apply on an \nannual basis for allocating taxes to \nseparate categories before any income is \nrecharacterized.\nIf prior year separate limitation losses \ncan be recaptured, the total amounts \nrecharacterized should be entered into the \nbold-outlined boxes as negative numbers. \nEach prior-year separate limitation loss \nrecaptured should be entered as a \npositive number on the same line under \nthe appropriate column heading to which \nincome was recharacterized.\nNote. The numbers entered across any \ngiven line should equal zero.\nExample 3. Assume the same facts as \nin Example 1 on page 1. Also assume \nthat, in a subsequent tax year, Corporation \nX has $1,500 of income in its general \ncategory (on line 8, column (iv), of its \nSchedule J).\nSince there is not enough general \ncategory income to recapture the entire \n$2,000 prior-year balance remaining to be \nrecaptured, Corporation X will prorate the \n$1,500 of general category income in that \nsubsequent year as follows.\n• To compute the portion to be \nrecharacterized as passive category \nincome, Corporation X should:\n1.\nDivide the $1,600 remaining to be \nrecharacterized from general category \nincome to passive category income by the \n$2,000 remaining to be recharacterized \nfrom general category income to all \nseparate categories;\n2.\nMultiply the result (80%) by the \n$1,500 of general category income; and\n3.\nEnter $1,200 as a positive number \non line 9d, column (iii).\n• To compute the portion to be \nrecharacterized as resourced treaty \nincome, Corporation X should:\n1.\nDivide the $400 remaining to be \nrecharacterized from general category \nincome to resourced treaty income by \n$2,000;\n2.\nMultiply the result (20%) by the \n$1,500 of general category income; and\n3.\nEnter $300 as a positive number on \nline 9d, column (v).\nCorporation X enters the $1,500 of \ngeneral category income that was \nrecharacterized in the bold-outlined box \non line 9d, column (iv). Note that the total \namounts entered across line 9d equal \nzero.\nFinally, Corporation X completes the \nPart II recharacterization balances grid by \nentering $400 ($1,600 minus $1,200) on \nline d, column (iii), and $100 ($400 minus \n$300) on line d, column (v).\nLine 10. Recapture overall domestic \nlosses that reduced separate limitation \nincome in prior tax years (section 904(g)\n(1)). To do this, treat a portion of the \ncurrent year U.S. source income as \nseparate limitation income in the same \ncategory(ies) as the separate limitation \nincome that was reduced by the prior year \noverall domestic loss. Recapture \ncontinues until the applicable overall \ndomestic loss account balance (Part IV) is \nreduced to zero. Enter the total overall \ndomestic loss recapture amount as a \nnegative number in column (vi). Enter the \namount recharacterized as separate \nlimitation income in each category, as \nappropriate, as positive numbers in \ncolumns (i) through (v).\nNote. The numbers entered across this \nline should equal zero.\nThe total amount of any current year \nU.S. income subject to recapture is the \nsmaller of the total balance in the \napplicable overall domestic loss accounts \n(the applicable column(s) in Part IV, line 1) \nor 50% of the amount entered on Part I, \nline 6.\nNote. Under the Tax Cuts and Jobs Act, \nsection 904(g)(5) allows for an election to \nrecapture up to 100% of any pre-2018 \nunused overall domestic loss from a prior \nyear, as opposed to the 50% stated in the \nprevious paragraph. This election is \napplicable for any taxable year beginning \nafter December 31, 2017, and before \nJanuary 1, 2028.\nIf a prior year overall domestic loss or \nlosses were allocated to more than one \nseparate category and there is not \nenough income in the current year subject \nto recharacterization to recapture all \nremaining overall domestic loss account \nbalances, then the current year U.S. \nsource income subject to \nrecharacterization must be \nrecharacterized as income of the separate \ncategories on a pro rata basis in the \nfollowing manner:\nCurrent year U.S. source income \nsubject to recharacterization x (Amount \nremaining to be recharacterized as \nincome of a given separate category / \nAmounts remaining to be recharacterized \nas income of all separate categories)\nPart II\nIf a separate limitation loss was allocated \nin a prior tax year and the corporation has \nincome during the current tax year in the \nseparate category from which the loss was \nallocated, that current year income (if it \nwas not previously recharacterized) must \nbe recharacterized as income of the \nInstructions for Schedule J (Form 1118) (Rev. Dec. 2020)\n-3-\n", "category to which the loss was allocated in \nthe prior year(s) (section 904(f)(5)).\nTo determine the amounts to enter into \nthe grid:\n1.\nAdd the current year separate \nlimitation loss allocations (adjusted as \nrequired by Regulations section \n1.904(b)-1(h)(1) relating to capital gains) \nto last year's year-end balances;\n2.\nNet any offsetting separate \nlimitation loss accounts as described in \nthe instructions for Part I, line 2;\n3.\nSubtract the amounts \nrecharacterized during the current tax \nyear; and\n4.\nEnter the result on the line (line a, \nb, c, d, or e) for the separate category \nfrom which losses were previously \nallocated, under the appropriate column \n(column (i), (ii), (iii), (iv) or (v)) to which the \nlosses were previously allocated.\nExample 4. Assume the same facts as \nin Example 1 on page 1. Also assume that \nCorporation X does not have any \nremaining balances from any prior \nallocations of losses from its general \ncategory to its passive category or its \nresourced treaty income category. The \ncorporation should enter $1,600 on line d, \ncolumn (iii), and $400 on line d, column \n(v).\nPart III\nLine 1. Enter the ending balances from \nlast year's schedule.\nLines 2, 3, and 4. Show any adjustments \nmade to the overall foreign loss accounts \nfor each separate category during the tax \nyear. See Regulations section \n1.904(f)-1(d) for a list of possible additions \nto the accounts. See Regulations section \n1.904(f)-1(e) for a list of possible \nreductions (including recapture).\nLine 5. Enter the year-end balances of \nthe overall foreign loss accounts for each \nseparate category.\nPart IV\nLine 1. Enter the ending balances from \nlast year's schedule.\nLines 2, 3, and 5. Show any adjustments \nmade to the overall domestic loss account \nwith respect to each separate category \nduring the tax year. See Regulations \nsection 1.904(g)-1(d) for a list of possible \nadditions to the accounts. See \nRegulations section 1.904(g)-1(e) for a list \nof possible reductions (including \nrecapture).\nNote. A U.S. source loss that is carried \nback as part of a net operating loss to \noffset foreign income in a prior qualified \ntax year will result in an increase to the \noverall domestic loss account in the year \nin which the loss arose, not the earlier year \nto which the loss was carried back to \noffset the foreign income.\nLine 6. Enter the year-end balances of \nthe overall domestic loss account with \nrespect to each separate category.\n-4-\nInstructions for Schedule J (Form 1118) (Rev. Dec. 2020)\n" ]
p5473sp.pdf	0121 Publ 5473 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5473sp.pdf	[ "www.eftps.gov/eftps \nwww.irs.gov \nHaga pagos más eficientes del plan de bancarrota \nCapítulo 13 del IRS – pague electrónicamente.\nDisfrute de los \nbeneficios\n• Reduzca la posibilidad de robo de \nidentidad\n• Ahorre en costos de franqueo y \npapeleo\n• Elimine errores humanos\n• Simplifique los procesos \ncomerciales \n• Obtenga un procesamiento rápido \ny preciso\n• Realice pagos 24/7 sin demora\n• Reduzca cargas\n• Evite problemas con cheques \nobsoletos\nCualquier persona que participe en el Centro \nNacional de Datos no necesita enviar cupones de \npago y listas de contabilidad al IRS.\nPublication 5473 (sp) (1-2021) Catalog Number 75263H Department of the Treasury Internal Revenue Service www.irs.gov\nPara más información, visite Consejos del IRS para Fideicomisarios de Bancarrota en IRS.gov.\nInscríbase ahora\nSiga estos 3 pasos para configurar el \nEFTPS para pagos de reclamaciones.\n1. Complete y envíe el Formulario \n14781, Inscripción en el \nSistema de Pago Electrónico de \nImpuestos Federales (EFTPS) para \ninsolvencia. La manera preferida \nde enviar el formulario es por fax \nal 855-536-3484. El IRS envía el \nFormulario 14781 a First Data para su \nprocesamiento. \n2. Reciba el número de inscripción de \nEFTPS® (número de identificación del \nfideicomisario) de First Data.\n3. Trabaje con un proveedor de \nsoftware y un banco para establecer \nla transferencia electrónica de \nfondos para poder realizar pagos de \nreclamación de EFTPS a través de la \nACH.\nÚnase a la mayoría de los fideicomisarios del Capítulo 13 y use el Sistema de Pago Electrónico de \nImpuestos Federales (EFTPS®) para enviar pagos de reclamaciones al IRS. Es gratis, rápido y seguro.\n" ]
p5473.pdf	0121 Publ 5473 (PDF)	https://www.irs.gov/pub/irs-pdf/p5473.pdf	[ "www.eftps.gov/eftps \nwww.irs.gov \nMake Chapter 13 bankruptcy plan payments to \nthe IRS more efficiently – pay electronically.\nEnjoy the Benefits\n• Reduce the chance of identity \ntheft\n• Save on postage and paper \ncosts\n• Eliminate human errors\n• Streamline business processes\n• Get fast, accurate processing \n• Make payments 24/7 without \ndelay \n• Reduce burdens\n• Avoid issues with stale-dated \nchecks\nAnyone participating with the National Data \nCenter doesn’t need to send payment vouchers \nand accounting lists to the IRS.\nPublication 5473 (1-2021) Catalog Number 75182N Department of the Treasury Internal Revenue Service www.irs.gov\nFor more information, visit IRS Tips for Bankruptcy Trustees on IRS.gov.\nEnroll Now\nFollow these 3 steps to set up \nEFTPS for claim payments.\n1. Complete and submit Form \n14781, Electronic Federal \nTax Payment System (EFTPS) \nInsolvency Registration PDF. \nThe preferred way to submit the \nform is by fax to 855-536-3484. \nThe IRS sends Form 14781 to First \nData for processing. \n2. Receive EFTPS® registration \nnumber (Trustee ID) from First \nData.\n3. Work with software provider and \nbank to set up the electronic funds \ntransfer for making EFTPS® claim \npayments via Automated Clearing \nHouse.\nJoin most Chapter 13 trustees and use the Electronic Federal Tax Payment System \n(EFTPS®) to submit claim payments to the IRS. It’s free, quick and secure.\n" ]
f8879sp.pdf	0121 Form 8879 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/f8879sp.pdf	[ "Formulario 8879(SP)\n(Rev. enero de 2021) \nAutorización de Firma para Presentar la Declaración por medio del IRS e-file\nDepartment of the Treasury \nInternal Revenue Service\n▶ El ERO tiene que obtener y conservar el Formulario 8879(SP) completado. \n▶ Visite www.irs.gov/Form8879SP para obtener la información más reciente. \nOMB No. 1545-0074\nNúmero de identificación de presentación (SID, por sus siglas en inglés) \n▲\nNombre del contribuyente\nNúmero de Seguro Social\nNombre del cónyuge\nNúmero de Seguro Social del cónyuge\nParte I\nInformación obtenida de su declaración de impuestos para el año tributario que termina el 31 de diciembre \nde \n(Anote el año que está autorizando y anote las cantidades en dólares enteros solamente).\nNota: Los declarantes del Formulario 1040-SS o del Formulario 1040-PR completan la línea 4 solamente y dejan las líneas 1, 2, 3 y 5 en blanco.\n1\nIngreso bruto ajustado .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n1\n2\nImpuesto total \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2\n3\nImpuesto federal sobre el ingreso retenido del (de los) Formulario(s) W-2 y Formulario(s) 1099 .\n.\n.\n.\n.\n.\n.\n3\n4\nReembolso\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4\n5\nCantidad que usted adeuda \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n5\nParte II\nDeclaración del contribuyente y autorización para la firma (Asegúrese de obtener y guardar una copia \nde su declaración de impuestos).\nPIN del contribuyente: marque sólo un recuadro\nAutorizo a\nNombre de la empresa ERO\npara anotar o crear mi PIN \nAnote cinco dígitos, sin \nque sean todos cero\ncomo mi firma\nen la declaración electrónica del impuesto sobre el ingreso (original o enmendada) para el año \ntributario que estoy autorizando.\nAnotaré mi PIN como mi firma para la declaración electrónica del impuesto sobre el ingreso (original o enmendada) para el año tributario que estoy \nautorizando. Marque este recuadro únicamente si anota su propio PIN y presenta su declaración utilizando el Método del PIN del Preparador \nProfesional. El ERO tiene que completar la Parte III a continuación.\nSu firma ▶\nFecha ▶\nPIN del cónyuge: marque sólo un recuadro\nAutorizo a\nNombre de la empresa ERO\npara anotar o crear mi PIN \nAnote cinco dígitos, sin \nque sean todos cero\ncomo mi firma\nen la declaración electrónica del impuesto sobre el ingreso (original o enmendada) para el año \ntributario que estoy autorizando.\nAnotaré mi PIN como mi firma para la declaración electrónica del impuesto sobre el ingreso (original o enmendada) para el año tributario que estoy \nautorizando. Marque este recuadro únicamente si anota su propio PIN y presenta su declaración utilizando el Método del PIN del Preparador \nProfesional. El ERO tiene que completar la Parte III a continuación.\nFirma del cónyuge ▶\nFecha ▶\nSólo para declaraciones utilizando el Método del PIN del Preparador Profesional —continúe con la parte siguiente\nParte III\nCertificación y autenticación —Sólo para el Método del PIN del Preparador Profesional\nEFIN/PIN del ERO. Anote su EFIN de seis dígitos seguido de su PIN de cinco dígitos seleccionado \npor usted.\nLos dígitos no pueden ser todos cero\nFirma del ERO ▶\nFecha ▶\nEl ERO tiene que conservar este formulario —Vea las instrucciones \nNo presente este formulario ante el IRS, a menos que se le requiera\nPara el Aviso sobre la Ley de Reducción de Trámites, vea las instrucciones de su declaración.\nCat. No. 38922N\nForm 8879 (SP) (Rev. 1-2021)\nBajo pena de perjurio, declaro haber examinado una copia de la declaración electrónica del impuesto sobre el ingreso (original o enmendada) para el año tributario que estoy autorizando y, \nsegún mi leal saber y entender, es verídica, correcta y completa. Declaro además que las cantidades provistas anteriormente en la Parte I son las mismas indicadas en la declaración \nelectrónica del impuesto sobre el ingreso (original o enmendada) para el año tributario que estoy autorizando. Autorizo a que mi proveedor intermediario de servicios, transmisor o iniciador de \ndeclaraciones electrónicas (ERO, por sus siglas en inglés) envíe mi declaración al IRS y que reciba del mismo (a) acuse de recibo o justificación de rechazo de la transmisión, (b) la razón por \ntoda demora en la tramitación de la declaración o reembolso y (c) la fecha de todo reembolso. Si corresponde, autorizo al U.S. Treasury (Departamento del Tesoro de los Estados Unidos) y a \nsu Agente Financiero designado para que tramiten ante la ACH una transacción de retiro electrónico de fondos (débito directo) en la cuenta de la institución financiera indicada en el programa \nde computadora (software) de preparación de declaraciones para pagar los impuestos federales que adeudo en esta declaración y/o pagar el impuesto estimado, y además autorizo a la \ninstitución financiera para que cargue la entrada a esta cuenta. Esta autorización quedará en pleno vigor hasta que yo notifique al Agente Financiero del Departamento del Tesoro de los \nEstados Unidos para que éste cancele la autorización. Para revocar (cancelar) un pago, tengo que comunicarme con el Agente Financiero del Departamento del Tesoro de los Estados Unidos \nal 1-888-353-4537. Las solicitudes de cancelación de pago se tienen que recibir a más tardar 2 días laborables antes de la fecha de pago (liquidación). También autorizo a las instituciones \nfinancieras que participan en la tramitación del pago electrónico de impuestos para que reciban información confidencial necesaria para responder a preguntas y resolver dudas relacionadas \ncon dicho pago. Certifico además que el número de identificación personal (PIN, por sus siglas en inglés) que aparece a continuación es mi firma para la declaración electrónica del impuesto \nsobre el ingreso (original o enmendada) para el año tributario que estoy autorizando y, si corresponde, mi consentimiento para el retiro de fondos por vías electrónicas.\nCertifico que el número anotado anteriormente es mi PIN, el cual sirve como mi firma para la presentación electrónica de la declaración del impuesto sobre el ingreso \n(original o enmendada) que estoy autorizado a presentar para el año tributario (indicado anteriormente) para el (los) contribuyente(s) indicado(s) anteriormente. Confirmo que \npresento esta declaración conforme a los requisitos del Método del PIN del Preparador Profesional y la Publicación 1345, Handbook for Authorized IRS e-file Providers of \nIndividual Income Tax Returns (Guía para proveedores autorizados de servicios de IRS e-file de declaraciones del impuesto sobre el ingreso personal), en inglés. \n", "Formulario 8879 (SP) (Rev. 1-2021)\nPágina 2\nInstrucciones Generales\nLas secciones a las cuales se hace referencia a \ncontinuación corresponden al Código Federal de \nImpuestos Internos, a menos que se indique lo \ncontrario.\nAcontecimientos futuros. Para obtener la \ninformación más reciente sobre \nlos acontecimientos relacionados al Formulario \n8879(SP) y sus instrucciones, tales como \nlegislación promulgada después de que éstos se \nhan publicado, visite www.irs.gov/Form8879SP.\nQué hay de nuevo. Puede usar esta nueva \nversión del Formulario 8879(SP) para autorizar la \npresentación electrónica de su declaración \noriginal o enmendada. Use este Formulario \n8879(SP) (Rev. enero de 2021) para los años \ntributarios de 2019 en adelante (Formulario 1040, \n1040-SR, 1040-NR, 1040-SS, 1040-PR o 1040-X).\nPropósito del Formulario\nEl Formulario 8879(SP) es el documento de \ndeclaración y autorización de firma para una \ndeclaración de impuestos presentada \nelectrónicamente por medio de un iniciador de \ndeclaraciones electrónicas (ERO, por sus siglas \nen inglés). Complete el Formulario 8879(SP) cada \nvez que se utilice el Método del PIN del \nPreparador Profesional o cuando el \ncontribuyente autorice a su ERO para que éste \nanote o cree el número de identificación personal \n(PIN, por sus siglas en inglés) del contribuyente \nen su declaración del impuesto sobre el ingreso \npersonal presentada por medio de e-file.\n▲\n!\nPRECAUCIÓN\nNo envíe este formulario al IRS. El \nERO tiene que conservar el \nFormulario 8879(SP).\nCuándo y Cómo Completar el \nFormulario\nUtilice este diagrama para determinar cuándo y \ncómo se completa el Formulario 8879(SP).\nSI el ERO. . .\nENTONCES. . .\nNo utiliza el Método del \nPIN del Preparador \nProfesional y el \ncontribuyente anota su \npropio PIN\nNo complete el \nFormulario \n8879(SP).\nNo utiliza el Método del \nPIN del Preparador \nProfesional y está \nautorizado a anotar o \ncrear el PIN del \ncontribuyente\nComplete las Partes \nI y II del Formulario \n8879(SP).\nUtiliza el Método del PIN \ndel Preparador Profesional \ny está autorizado a anotar \no crear el PIN del \ncontribuyente\nComplete las Partes \nI, II y III del \nFormulario \n8879(SP).\nUtiliza el Método del PIN \ndel Preparador Profesional \ny el contribuyente anota \nsu propio PIN\nComplete las Partes \nI, II y III del \nFormulario \n8879(SP).\nResponsabilidades del ERO\nEl ERO tiene que:\n1. Escribir el (los) nombre(s) y número(s) de \nSeguro Social del (de los) contribuyente(s) en la \nparte superior de este formulario.\n2. Completar la Parte I utilizando las cantidades \n(incluyendo los ceros, cuando corresponda) \nreflejadas en la declaración de impuestos del \ncontribuyente. Los declarantes del Formulario \n1040-SS o del Formulario 1040-PR deben dejar en \nblanco las líneas 1 a 3 y la línea 5.\n3. Anotar o crear un PIN para el contribuyente, \nsi éste lo autoriza, y luego anotarlo en los \nrecuadros provistos en la Parte II.\n4. Escribir en la línea para la autorización de la \nParte II el nombre de la empresa ERO (no el \nnombre del individuo que prepara la declaración) \nsi el ERO está autorizado para anotar el PIN del \ncontribuyente.\n5. Proveer al contribuyente el Formulario \n8879(SP) para que él lo complete y lo revise en \npersona o por envío a través del Servicio Postal \nde los EE.UU., servicio de entrega privado, \ncorreo electrónico (email), sitio web o fax.\n6. Anotar el número de identificación de \npresentación (SID, por sus siglas en inglés) de 20 \ndígitos asignado a la declaración de impuestos, o \njuntar el Formulario 9325, Acknowledgement and \nGeneral Information for Taxpayers Who File Returns \nElectronically (Acuse de recibo e información \ngeneral para contribuyentes que presentan \ndeclaraciones electrónicamente), en inglés, con el \nFormulario 8879(SP) (o el Formulario 8879, en \ninglés) después de presentar la declaración. Si \nutiliza el Formulario 9325 para proveer el SID, no \nse requiere que lo adjunte físicamente al \nFormulario 8879(SP). Sin embargo, tiene que \nguardarlo conforme a los requisitos de retención \npublicados para el Formulario 8879(SP). Vea la \nPublicación 4164, Modernized e-File (MeF) Guide \nfor Software Developers and Transmitters (Guía del \nsistema e-file actualizado para los desarrolladores \nde programas de computadora (software) y \ntransmisores de declaraciones electrónicas), \ndisponible en inglés, para más detalles.\n▲\n!\nPRECAUCIÓN\nUsted tiene que recibir del \ncontribuyente un Formulario 8879(SP), \ndebidamente completado y firmado, \nantes de transmitir la declaración \nelectrónica (o autorizar su transmisión).\nPara obtener información adicional, vea la \nPublicación 1345, disponible en inglés.\nResponsabilidades del \nContribuyente\nEl contribuyente tiene que:\n1. Verificar la exactitud de la declaración del \nimpuesto sobre el ingreso que ha sido \npreparada, incluyendo información sobre el \nmétodo de depósito directo.\n2. Marcar el recuadro correspondiente de la \nParte II para autorizar al ERO a anotar o crear el \nPIN del contribuyente o para hacerlo usted mismo.\n3. Indicar o verificar su PIN al autorizar al ERO \na anotarlo o crearlo (el PIN tiene que ser de cinco \ndígitos que no sean todos cero).\n4. Firmar y fechar el Formulario 8879(SP). Los \ncontribuyentes tienen que firmar el Formulario \n8879(SP) de su puño y letra o por firma \nelectrónica si es compatible con el programa de \ncomputadora (software).\n5. Devolver el Formulario 8879(SP) \ndebidamente completado al ERO en persona o \npor envío a través del Servicio Postal de los \nEE.UU., servicio de entrega privado, correo \nelectrónico (email), sitio web o fax.\nLa declaración de impuestos no será \ntransmitida al IRS hasta que el ERO reciba el \nFormulario 8879(SP) firmado por el contribuyente.\nInformación sobre su reembolso. Usted puede \ncomprobar el estado de su reembolso si han \npasado al menos 72 horas desde que el IRS \nacusó recibo de su declaración electrónica. Pero \nsi presentó el Formulario 8379, Injured Spouse \nAllocation (Asignación del cónyuge perjudicado), \nen inglés, con su declaración, permita 11 \nsemanas. Para comprobar el estado de su \nreembolso, opte por una de las siguientes \nalternativas:\n• Visite www.irs.gov/Reembolsos.\n• Llame al 800-829-4477 para escuchar \ninformación automatizada sobre reembolsos y \nsiga las instrucciones grabadas.\n• Llame al 800-829-1954.\nPuntos Importantes para los ERO\n• No envíe el Formulario 8879(SP) al IRS, a \nmenos que se le requiera. Conserve el \nFormulario 8879(SP) completado durante 3 años \na partir de la fecha límite para presentar la \ndeclaración o la fecha en que el IRS la haya \nrecibido, lo que ocurra más tarde. Se puede \nconservar el Formulario 8879(SP) en forma \nelectrónica conforme a las pautas para el \nmantenimiento de documentación que se \nencuentran en el Revenue Procedure 97-22 \n(Procedimiento Administrativo Tributario 97-22 o \nRev. Proc. 97-22, por su abreviatura en inglés) \nque se encuentra en la página 9 del Internal \nRevenue Bulletin 1997-13 (Boletín de Impuestos \nInternos 1997-13), disponible en inglés, en \nwww.irs.gov/pub/irs-irbs/irb97-13.pdf.\n• Verifique la identidad del (de los) \ncontribuyente(s). \n• Complete la Parte III únicamente si presenta la \ndeclaración utilizando el Método del PIN del \nPreparador Profesional. No se le exige anotar la \nfecha de nacimiento del contribuyente, la cantidad \nde ingreso bruto ajustado del año anterior ni el \nPIN en el registro de autenticación de la \ndeclaración presentada por vías electrónicas.\n• Si usted no utiliza el Método del PIN del \nPreparador Profesional, anote la fecha de \nnacimiento del contribuyente (o contribuyentes) y \nel ingreso bruto ajustado o el PIN, o ambos, de la \ndeclaración de impuestos del contribuyente que \nse presentó originalmente para el año anterior en \nel registro de autenticación de la declaración \npresentada electrónicamente por el \ncontribuyente. No utilice cantidades de una \ndeclaración enmendada o de una corrección a \nun error matemático hecha por el IRS.\n• Ingrese el (los) PIN del contribuyente en la \npantalla para la entrada de datos sólo si él lo \nautoriza. Si se trata de una declaración de \nimpuestos de casados que presentan una \ndeclaración conjunta, se le permite a uno de los \ncónyuges autorizar al ERO para que éste anote \nsu PIN mientras el otro cónyuge anota el PIN \nsuyo. No se le permite al contribuyente escoger \nni anotar el PIN de un cónyuge ausente.\n• Los contribuyentes tienen que usar un PIN para \nfirmar la declaración de impuestos sobre el \ningreso personal presentada electrónicamente y \ntransmitida por un ERO.\n• Entregue al contribuyente una copia del \nFormulario 8879(SP) firmado para su \ndocumentación si éste se la pide.\n• Entregue al contribuyente una copia del \nFormulario 8879(SP) corregido si se le hacen \ncambios a la declaración (por ejemplo, basados \nen una revisión por el contribuyente).\n• Los ERO pueden firmar el Formulario \n8879(SP) por medio de un sello de goma, \naparato mecánico (como un bolígrafo \nelectrónico) o programa de computadora \n(software). Vea el Notice 2007-79 (Aviso \n2007-79) que se encuentra en la página 809 \ndel Internal Revenue Bulletin 2007-42 (Boletín \nde Impuestos Internos 2007-42), disponible \nen inglés, en www.irs.gov/\nirb/2007-42_IRB#NOT-2007-79 para más \ninformación.\n• Para más información, visite www.irs.gov/\nEfile y pulse sobre Español.\n" ]
i8275.pdf	0121 Inst 8275 (PDF)	https://www.irs.gov/pub/irs-pdf/i8275.pdf	[ "Instructions for Form 8275\n(Rev. January 2021)\n(For use with Form 8275 (Rev. August 2013))\nDisclosure Statement\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal \nRevenue Code unless otherwise noted.\nFuture Developments\nFor the latest information about \ndevelopments related to Form 8275 \nand its instructions, such as \nlegislation enacted after they were \npublished, go to IRS.gov/Form8275.\nGeneral Instructions\nPurpose of Form\nForm 8275 is used by taxpayers and \ntax return preparers to disclose items \nor positions, except those taken \ncontrary to a regulation, that are not \notherwise adequately disclosed on a \ntax return to avoid certain penalties. \nThe form is filed to avoid the portions \nof the accuracy-related penalty due to \ndisregard of rules or to a substantial \nunderstatement of income tax for \nnon-tax shelter items if the return \nposition has a reasonable basis. It can \nalso be used for disclosures relating \nto the economic substance penalty \nand the preparer penalties for tax \nunderstatements due to unreasonable \npositions or disregard of rules.\nThe portion of the \naccuracy-related penalty \nattributable to the following \ntypes of misconduct cannot be \navoided by disclosure on Form 8275.\n• Negligence.\n• Disregard of regulations.\n• Any substantial understatement of \nincome tax on a tax shelter item.\n• Any substantial or gross valuation \nmisstatement (including \nmisstatements attributable to \nnon-arm's length prices) under \nchapter 1.\n• Any substantial overstatement of \npension liabilities.\n• Any substantial estate or gift tax \nvaluation understatements.\n• Any claim of tax benefits from a \ntransaction lacking economic \nsubstance (within the meaning of \nsection 7701(o)) or failing to meet the \nCAUTION\n!\nrequirements of any similar rule of \nlaw.\n• Any otherwise undisclosed foreign \nfinancial asset understatement.\n• Any inconsistent estate basis.\nWho Should File\nForm 8275 is filed by individuals, \ncorporations, pass-through entities, \nand tax return preparers. If you are \ndisclosing a position taken contrary to \na regulation, use Form 8275-R, \nRegulation Disclosure Statement, \ninstead of Form 8275.\nFor items attributable to a \npass-through entity, disclosure should \nbe made on the tax return of the \nentity. If the entity does not make the \ndisclosure, the partner (or \nshareholder, etc.) can make adequate \ndisclosure of these items.\nException to filing Form 8275. \nGuidance is published annually in a \nrevenue procedure in the Internal \nRevenue Bulletin that identifies \ncircumstances when an item reported \non a return is considered adequate \ndisclosure for purposes of the \nsubstantial understatement aspect of \nthe accuracy-related penalty and for \navoiding the preparer's penalty \nrelating to understatements due to \nunreasonable positions. See the \nExample below. You do not have to \nfile Form 8275 for items that meet the \nrequirements listed in this revenue \nprocedure. This revenue procedure \ncan be found on the internet at \nIRS.gov.\nExample. Generally, you will have \nmet the requirements for adequate \ndisclosure of a charitable contribution \ndeduction if you complete the \ncontributions section of Schedule A \n(Form 1040), supply all required \ninformation, and attach all related \nforms required pursuant to statute or \nregulation.\nHow To File\nFile Form 8275 with your original tax \nreturn. Keep a copy for your records. \nYou may be able to file Form 8275 \nwith an amended return. See \nRegulations sections 1.6662-4(f)(1) \nand 1.6664-2(c)(3) for more \ninformation.\nTo make adequate disclosure for \nitems reported by a pass-though \nentity, you must complete and file a \nseparate Form 8275 for items \nreported by each entity.\nTo make adequate disclosure for a \nposition or positions related to more \nthan one foreign entity, you must \ncomplete and file a separate Form \n8275 for each foreign entity.\nCarryovers, carrybacks, and recur-\nring items. Carryover items must be \ndisclosed for the tax year in which \nthey originated. You do not have to file \nanother Form 8275 for those items for \nthe tax years in which the carryover is \ntaken into account.\nCarryback items must be disclosed \nfor the tax year in which they \noriginated. You do not have to file \nanother Form 8275 for those items for \nthe tax years in which the carryback is \ntaken into account.\nHowever, if you disclose items of a \nrecurring nature (such as depreciation \nexpense), you must file Form 8275 for \neach tax year in which the item \noccurs.\nIf you are disclosing a position that \nis contrary to a rule, and the position \nrelates to a reportable transaction as \ndefined in Regulations section \n1.6011-4(b), you must also make the \ndisclosure as indicated in Regulations \nsection 1.6011-4(d). See Form 8886, \nReportable Transaction Disclosure \nStatement, and its instructions; Notice \n2006-6, 2006-5 I.R.B. 385, available \nat IRS.gov/irb/2006-05_IRB/\nar10.html; and Notice 2010-62, \n2010-40 I.R.B. 411, available at \nIRS.gov/irb/2010-40_IRB/ar09.html.\nAccuracy-Related Penalty\nGenerally, the accuracy-related \npenalty is 20% of any portion of a tax \nunderpayment attributable to:\nOct 20, 2020\nCat. No. 62063F\n", "1. Negligence or disregard of rules \nor regulations;\n2. Any substantial understatement \nof income tax;\n3. Any substantial valuation \nmisstatement under chapter 1 of the \nInternal Revenue Code;\n4. Any substantial overstatement \nof pension liabilities;\n5. Any substantial estate or gift tax \nvaluation understatement;\n6. Any claim of tax benefits from a \ntransaction lacking economic \nsubstance, as defined by section \n7701(o), or failing to meet the \nrequirements of any similar rule of \nlaw;\n7. Any undisclosed foreign \nfinancial asset understatement; or\n8. Any inconsistent estate basis.\nThe penalty is 40% of any portion \nof a tax underpayment attributable to \none or more gross valuation \nmisstatements in (3), (4), or (5) above \nif the applicable dollar limitation under \nsection 6662(h)(2) is met. The penalty \nalso increases to 40% for failing to \nadequately disclose a transaction that \nlacks economic substance in (6) \nabove. See Economic substance \nbelow. The penalty is 40% of any \nportion of an underpayment that is \nattributable to any undisclosed foreign \nfinancial asset understatement.\nEconomic substance. To satisfy the \ndisclosure requirements under section \n6662(i), you may adequately disclose \nwith a timely filed original return \n(determined with regard to \nextensions) or a qualified amended \nreturn (as defined under Regulations \nsection 1.6664-2(c)(3)) the relevant \nfacts affecting the tax treatment of the \ntransaction.\nNote. If you filed a Schedule UTP \n(Form 1120), you may not need to file \nForm 8275 to satisfy the disclosure \nrequirements of section 6662(i). See \nthe Instructions for Schedule UTP \n(Form 1120).\nReasonable cause exception. \nGenerally, no accuracy-related \npenalty will be imposed on any portion \nof an underpayment if you show that \nthere was reasonable cause for that \nportion and that you acted in good \nfaith with respect to that portion.\nThe reasonable cause and \ngood faith exception does not \napply to any portion of an \nunderpayment attributable to a \ntransaction that lacks economic \nsubstance under section 7701(o).\nAdequate disclosure. Generally, \nyou can avoid the disregard of rules \nand substantial understatement \nportions of the accuracy-related \npenalty if the position is adequately \ndisclosed and the position has at least \na reasonable basis. To avoid the \ndisregard of regulations portion of the \naccuracy-related penalty, the position \ntaken must also represent a \ngood-faith challenge to the validity of \nthe regulation. See Regulations \nsection 1.6662-3(c)(1).\nReasonable basis. Reasonable \nbasis is a relatively high standard of \ntax reporting that is significantly higher \nthan not frivolous or not patently \nimproper. The reasonable basis \nstandard is not satisfied by a return \nposition that is merely arguable.\nIf the return position is reasonably \nbased on one of the authorities set \nforth in Regulations section \n1.6662-4(d)(3)(iii) (taking into account \nthe relevance and persuasiveness of \nthe authorities, and subsequent \ndevelopments), the return position will \ngenerally satisfy the reasonable basis \nstandard even though it may not \nsatisfy the substantial authority \nstandard as defined in Regulations \nsection 1.6662-4(d)(2). For details, \nsee Regulations sections 1.6662-4(d); \n1.662-3(b)(3).\nIf you failed to keep proper books \nand records or failed to substantiate \nitems properly, you cannot avoid the \npenalty by disclosure.\nSubstantial Understatement\nAn understatement is the excess of:\n1. The amount of tax required to \nbe shown on the return for the tax \nyear, over\n2. The amount of tax imposed \nwhich is shown on the return for the \ntax year, reduced by any rebates.\nThere is a substantial \nunderstatement of income tax if the \namount of the understatement for any \ntax year exceeds the greater of:\n1. 10% of the tax required to be \nshown on the return for the tax year, \nor\nCAUTION\n!\n2. $5,000.\nAn understatement of a corporation \n(other than an S corporation or a \npersonal holding company, as defined \nin section 542) is substantial if it \nexceeds in any year the lesser of:\n1. 10% of the tax required to be \nshown on the return for the tax year \n(or, if greater, $10,000), or\n2. $10,000,000.\nReduction of understatement. The \namount of the understatement will be \nreduced by the part that is attributable \nto the following items.\n• An item (other than a tax shelter \nitem) for which there was substantial \nauthority for the treatment claimed at \nthe time the return was filed or on the \nlast day of the tax year to which the \nreturn relates.\n• An item (other than a tax shelter \nitem) that is adequately disclosed on \nthis form if there is a reasonable basis \nfor the tax treatment of the item. (In no \nevent will a corporation be treated as \nhaving a reasonable basis for its tax \ntreatment of an item attributable to a \nmulti-party financing transaction \nentered into after August 5, 1997, if \nthe treatment does not clearly reflect \nthe income of the corporation.)\nFor corporate tax shelter \ntransactions (and for tax shelter items \nof other taxpayers for tax years \nending after October 22, 2004), the \nonly exception to the substantial \nunderstatement portion of the \naccuracy-related penalty is the \nreasonable cause exception. For \nmore details, see Reasonable cause \nexception, earlier; section 6662(d); \nand Regulations section 1.6664-4.\nTax shelter items. A tax shelter, \nfor purposes of the substantial \nunderstatement portion of the \naccuracy-related penalty, is a \npartnership or other entity, plan, or \narrangement, with a significant \npurpose to avoid or evade federal \nincome tax. For transactions on or \nbefore August 5, 1997, a tax shelter is \na partnership or other entity, plan, or \narrangement, whose principal \npurpose is to avoid or evade federal \nincome tax.\nA tax shelter item is any item of \nincome, gain, loss, deduction, or \ncredit that is directly or indirectly \nattributable to the principal or \n-2-\nInstructions for Form 8275 (Rev. 1-2021)\n", "significant purpose of the tax shelter \nto avoid or evade federal income tax.\nTax Return Preparer Penalties\nA preparer who files a return or claim \nfor refund is subject to a penalty in an \namount equal to the greater of $1,000 \nor 50% of the income derived (or to be \nderived) by the tax return preparer, \nwith respect to the return or claim, for \ntaking a position which the preparer \nknew or reasonably should have \nknown would understate any part of \nthe liability if:\n• There is or was no substantial \nauthority for the position;\n• The position is a tax shelter (as \ndefined in section 6662(d)(2)(C)(ii)) or \na reportable transaction to which \nsection 6662A applies and it was not \nreasonable to believe that the position \nwould more likely than not be \nsustained on its merits; or\n• The position disclosed as provided \nin section 6662(d)(2)(B)(ii) is not a tax \nshelter or a reportable transaction to \nwhich section 6662A applies, and \nthere was no reasonable basis for the \nposition.\nThe penalty will not apply if it can \nbe shown that there was reasonable \ncause for the understatement and that \nthe preparer acted in good faith.\nIn cases where any part of the \nunderstatement of the liability is due \nto a willful attempt by the return \npreparer to understate the liability, or \nif the understatement is due to \nreckless or intentional disregard of \nrules or regulations by the preparer, \nthe preparer is subject to a penalty \nequal to the greater of $5,000 or 75% \nof the income derived (or to be \nderived) by the tax return preparer \nwith respect to the return or claim. \nThis penalty shall be reduced by the \namount of the penalty paid by such \nperson for taking an unreasonable \nposition, or a position with no \nreasonable basis, as described \nimmediately above.\nA preparer is not considered to \nhave recklessly or intentionally \ndisregarded a rule if a position is \nadequately disclosed and has a \nreasonable basis.\nNote. For more information about the \naccuracy-related penalty and preparer \npenalties, and the means of avoiding \nthese penalties, see the regulations \nunder sections 6662, 6664, and 6694.\nSpecific Instructions\nBe sure to supply all the information \nfor Parts I, II, and, if applicable, Part \nIII. Your disclosure will be considered \nadequate if you file Form 8275 and \nsupply the information requested in \ndetail.\nUse Part IV on page 2 if you need \nmore space for Part I or II. Indicate the \ncorresponding part and line number \nfrom page 1. You can use a \ncontinuation sheet(s) if you need \nadditional space. Be sure to put your \nname and identifying number on each \nsheet.\nReference ID number. If you are \nfiling Form 8275 to disclose a position \nrelated to a foreign entity for which an \ninformation return (such as Form \n5471) is filed, enter on Form 8275 the \nsame reference ID number for the \nforeign entity that is entered on the \ninformation return.\nIf you are filing Form 8275 to report \na position or positions related to \nmultiple foreign entities, file a \nseparate Form 8275 for each foreign \nentity.\nPart I\nColumn (a). If you are disclosing a \nposition contrary to a rule (such as a \nstatutory provision or IRS revenue \nruling), you must identify the rule in \ncolumn (a).\nColumn (b). Identify the item by \nname.\nIf any item you disclose is from a \npass-through entity, you must identify \nthe item as such. If you disclose items \nfrom more than one pass-through \nentity, you must complete a separate \nForm 8275 for each entity. Also, see \nHow To File, earlier.\nColumn (c). Enter a complete \ndescription of the item(s) you are \ndisclosing.\nExample. If entertainment \nexpenses were reported in column \n(b), then list in column (c) “theater \ntickets, catering expenses, and \nbanquet hall rentals.”\nIf you claim the same tax treatment \nfor a group of similar items in the \nsame tax year, enter a description \nidentifying the group of items you are \ndisclosing rather than a separate \ndescription of each item within the \ngroup.\nColumns (d) through (f). Enter the \nlocation of the item(s) by identifying \nthe form number or schedule and the \nline number in columns (d) and (e) \nand the amount of the item(s) in \ncolumn (f).\nPart II\nYour disclosure statement must \ninclude a description of the relevant \nfacts affecting the tax treatment of the \nitem. To satisfy this requirement, you \nmust include information that can \nreasonably be expected to apprise the \nIRS of the identity of the item, its \namount, and the nature of the \ncontroversy or potential controversy. \nInformation concerning the nature of \nthe controversy can include a \ndescription of the legal issues \npresented by the facts.\nUnless provided otherwise in \nthe General Instructions, \nearlier, your disclosure will not \nbe considered accurate unless the \ninformation described above is \nprovided using Form 8275. For \nexample, your disclosure will not be \nconsidered adequate if you attach a \ncopy of an acquisition agreement to \nyour tax return to disclose the issues \ninvolved in determining the basis of \ncertain acquired assets. If Form 8275 \nis not completed and attached to the \nreturn, the disclosure will not be \nconsidered valid even if the \ninformation described above is \nprovided using another method, such \nas a different form or an attached \nletter.\nPart III\nLine 4. Contact your pass-through \nentity if you do not know where its \nreturn was filed. However, for partners \nand S corporation shareholders, \ninformation for line 4 can be found on \nthe Schedule K-1 that you received \nfrom the partnership or S corporation.\nIf the pass-through entity filed its \nreturn electronically using e-file, enter \n“e-file” on line 4.\nPaperwork Reduction Act Notice. \nWe ask for the information on this \nform to carry out the Internal Revenue \nlaws of the United States. You are \nrequired to give us the information if \nyou wish to use this form to make \nadequate disclosure to avoid the \nportion of the accuracy-related \nCAUTION\n!\nInstructions for Form 8275 (Rev. 1-2021)\n-3-\n", "penalty due to a substantial \nunderstatement of income tax or \ndisregard of rules, or to avoid certain \npreparer penalties. We need it to \nensure that you are complying with \nthese laws and to allow us to figure \nand collect the right amount of tax.\nYou are not required to provide the \ninformation requested on a form that \nis subject to the Paperwork Reduction \nAct unless the form displays a valid \nOMB control number. Books or \nrecords relating to a form or its \ninstructions must be retained as long \nas their contents may become \nmaterial in the administration of any \nInternal Revenue law. Generally, tax \nreturns and return information are \nconfidential, as required by section \n6103.\nThe time needed to complete and \nfile this form will vary depending on \nindividual circumstances. The \nestimated burden for individual \ntaxpayers filing this form is approved \nunder OMB control number \n1545-0074 and is included in the \nestimates shown in the instructions for \ntheir individual income tax return. The \nestimated burden for all other \ntaxpayers who file this form is shown \nbelow.\nRecordkeeping. . . . . . .\n3 hr., 35 \nmin.\nLearning about the law\nor the form . . . . . . . .\n1 hr.\nPreparing and sending\nthe form to the IRS . .\n1 hr., 6 min.\nIf you have comments concerning \nthe accuracy of these time estimates \nor suggestions for making this form \nsimpler, we would be happy to hear \nfrom you. See the instructions for the \ntax return with which this form is filed.\n-4-\nInstructions for Form 8275 (Rev. 1-2021)\n" ]
f8822.pdf	0221 Form 8822 (PDF)	https://www.irs.gov/pub/irs-pdf/f8822.pdf	[ "Form 8822\n(Rev. February 2021)\nDepartment of the Treasury \nInternal Revenue Service \nChange of Address \n(For Individual, Gift, Estate, or Generation-Skipping Transfer Tax Returns)\n▶ Please type or print. ▶ See instructions on back. ▶ Do not attach this form to your return. \n▶ Information about Form 8822 is available at www.irs.gov/form8822. \nOMB No. 1545-1163\nPart I \nComplete This Part To Change Your Home Mailing Address \nCheck all boxes this change affects: \n1 \nIndividual income tax returns (Forms 1040, 1040-SR, 1040-NR, etc.) \n▶ If your last return was a joint return and you are now establishing a residence separate from the spouse with whom \nyou filed that return, check here .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\n2 \nGift, estate, or generation-skipping transfer tax returns (Forms 706, 709, etc.) \n▶ For Forms 706 and 706-NA, enter the decedent’s name and social security number below. \n▶ Decedent’s name \n▶ Social security number \n3a\nYour name (first name, initial, and last name) \n3b \nYour social security number \n4a\nSpouse’s name (first name, initial, and last name) \n4b \nSpouse’s social security number \n5a\nYour prior name(s). See instructions. \n5b\nSpouse’s prior name(s). See instructions. \n6a\nYour old address (no., street, apt. no., city or town, state, and ZIP code). If a P.O. box, see instructions. If foreign address, also complete spaces below, \nsee instructions. \nForeign country name\nForeign province/county\nForeign postal code\n6b \nSpouse’s old address, if different from line 6a (no., street, apt. no., city or town, state, and ZIP code). If a P.O. box, see instructions. If foreign address, also \ncomplete spaces below, see instructions.\nForeign country name\nForeign province/county\nForeign postal code\n7 \nNew address (no., street, apt. no., city or town, state, and ZIP code). If a P.O. box, see instructions. If foreign address, also complete spaces below, see \ninstructions.\nForeign country name\nForeign province/county\nForeign postal code\nPart II \nSignature \nDaytime telephone number of person to contact (optional) ▶\nSign \nHere \n▲\nYour signature \nDate \n▲\nSignature of representative, executor, administrator/if applicable \nDate \n▲\nIf joint return, spouse’s signature \nDate \n▲\nTitle \nFor Privacy Act and Paperwork Reduction Act Notice, see back of form. \nCat. No. 12081V \nForm 8822 (Rev. 2-2021) \n", "Form 8822 (Rev. 2-2021) \nPage 2 \nFuture Developments\nInformation about developments affecting \nForm 8822 (such as legislation enacted after \nwe release it) is at www.irs.gov/form8822.\nPurpose of Form \nYou can use Form 8822 to notify the Internal \nRevenue Service if you changed your home \nmailing address. If this change also affects \nthe mailing address for your children who \nfiled income tax returns, complete and file a \nseparate Form 8822 for each child. If you are \na representative signing for the taxpayer, \nattach to Form 8822 a copy of your power of \nattorney. Generally, it takes 4 to 6 weeks to \nprocess a change of address.\nChanging both home and business \naddresses? Use Form 8822-B to change \nyour business address.\nPrior Name(s) \nIf you or your spouse changed your name \nbecause of marriage, divorce, etc., complete \nline 5. Also, be sure to notify the Social \nSecurity Administration of your new name so \nthat it has the same name in its records that \nyou have on your tax return. This prevents \ndelays in processing your return and issuing \nrefunds. It also safeguards your future social \nsecurity benefits. \nAddresses \nBe sure to include any apartment, room, or \nsuite number in the space provided. \nP.O. Box \nEnter your box number instead of your street \naddress only if your post office does not \ndeliver mail to your street address. \nForeign Address \nFollow the country’s practice for entering the \npostal code. Please do not abbreviate the \ncountry. \n“In Care of” Address \nIf you receive your mail in care of a third party \n(such as an accountant or attorney), enter \n“C/O” followed by the third party’s name and \nstreet address or P.O. box. \nSignature \nThe taxpayer, executor, donor, or an \nauthorized representative must sign. If your \nlast return was a joint return, your spouse \nmust also sign (unless you have indicated by \nchecking the box on line 1 that you are \nestablishing a separate residence). \n▲\n!\nCAUTION\nIf you are a representative signing \non behalf of the taxpayer, you \nmust attach to Form 8822 a copy \nof your power of attorney. To do \nthis, you can use Form 2848. The Internal \nRevenue Service will not complete an \naddress change from an “unauthorized” third \nparty. \nWhere To File \n• If you checked the box on line 2, send \nForm 8822 to: Department of the \nTreasury, Internal Revenue Service \nCenter, Kansas City, MO 64999-0023.\n• If you did not check the box on line 2, \nsend Form 8822 to the address shown \nhere that applies to you:\nIF your old home mailing \naddress was in . . . \nTHEN use this \naddress . . . \nAlabama, Arkansas, \nDelaware, Georgia, Illinois, \nIndiana, Iowa, Kentucky, \nMaine, Massachusetts, \nMinnesota, Missouri, New \nHampshire, New Jersey, \nNew York, North Carolina, \nOklahoma, South Carolina, \nTennessee, Vermont, \nVirginia, Wisconsin\nDepartment of the \nTreasury \nInternal Revenue \nService \nKansas City, MO \n64999-0023 \nFlorida, Louisiana, \nMississippi, Texas \nDepartment of the \nTreasury \nInternal Revenue \nService \nAustin, TX \n73301-0023 \nAlaska, Arizona, California, \nColorado, Connecticut, \nDistrict of Columbia, \nHawaii, Idaho, Kansas, \nMaryland, Michigan, \nMontana, Nebraska, \nNevada, New Mexico, \nNorth Dakota, Ohio, \nOregon, Pennsylvania, \nRhode Island, South \nDakota, Utah, Washington, \nWest Virginia, Wyoming\nDepartment of the \nTreasury \nInternal Revenue \nService \nOgden, UT \n84201-0023 \nA foreign country, \nAmerican Samoa, or \nPuerto Rico (or are \nexcluding income under \nInternal Revenue Code \nsection 933), or use an \nAPO or FPO address, or \nfile Form 2555, 2555-EZ, \nor 4563, or are a dual-\nstatus alien or non bona \nfide resident of Guam or \nthe Virgin Islands.\nDepartment of the \nTreasury \nInternal Revenue \nService \nAustin, TX \n73301-0023 \nGuam: \nbona fide residents\nDepartment of \nRevenue and \nTaxation \nGovernment of \nGuam \nP.O. Box 23607 \nGMF, GU 96921 \nVirgin Islands: \nbona fide residents\nV.I. Bureau of \nInternal Revenue \n6115 Estate \nSmith Bay, \nSuite 225 \nSt. Thomas, VI 00802 \nPrivacy Act and Paperwork Reduction Act \nNotice. We ask for the information on this \nform to carry out the Internal Revenue laws of \nthe United States. Our legal right to ask for \ninformation is Internal Revenue Code sections \n6001 and 6011, which require you to file a \nstatement with us for any tax for which you \nare liable. Section 6109 requires that you \nprovide your social security number on what \nyou file. This is so we know who you are, and \ncan process your form and other papers. \nGenerally, tax returns and return \ninformation are confidential, as required by \nsection 6103. However, we may give the \ninformation to the Department of Justice and \nto other federal agencies, as provided by law. \nWe may give it to cities, states, the District of \nColumbia, and U.S. commonwealths or \npossessions to carry out their tax laws. We \nmay also disclose this information to other \ncountries under a tax treaty, to federal and \nstate agencies to enforce federal nontax \ncriminal laws, or to federal law enforcement \nand intelligence agencies to combat terrorism. \nThe use of this form is voluntary. However, \nif you fail to provide the Internal Revenue \nService with your current mailing address, you \nmay not receive a notice of deficiency or a \nnotice and demand for tax. Despite the failure \nto receive such notices, penalties and interest \nwill continue to accrue on the tax deficiencies. \nYou are not required to provide the \ninformation requested on a form that is \nsubject to the Paperwork Reduction Act \nunless the form displays a valid OMB control \nnumber. Books or records relating to a form \nor its instructions must be retained as long as \ntheir contents may become material in the \nadministration of any Internal Revenue law. \nThe time needed to complete and file this \nform will vary depending on individual \ncircumstances. The estimated average time is \n16 minutes. \nComments. You can send comments from \nwww.irs.gov/FormComments. Or you can write \nto the Internal Revenue Service, Tax Forms \nand Publications Division, 1111 Constitution \nAve. NW, IR-6526, Washington, DC 20224. DO \nNOT SEND THE FORM TO THIS ADDRESS. \nInstead, see Where To File, earlier.\n" ]
i8275r.pdf	0121 Inst 8275-R (PDF)	https://www.irs.gov/pub/irs-pdf/i8275r.pdf	[ "Instructions for\nForm 8275-R\n(Rev. January 2021)\n(For use with Form 8275-R (Rev. August 2013))\nRegulation Disclosure Statement\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal \nRevenue Code unless otherwise noted.\nFuture Developments\nFor the latest information about \ndevelopments related to Form 8275-R \nand its instructions, such as \nlegislation enacted after they were \npublished, go to IRS.gov/Form8275R.\nGeneral Instructions\nPurpose of Form\nForm 8275-R is used by taxpayers \nand tax return preparers to disclose \npositions taken on a tax return that are \ncontrary to Treasury regulations. The \nform is filed to avoid the portions of \nthe accuracy-related penalty due to \ndisregard of regulations or to a \nsubstantial understatement of income \ntax for non-tax shelter items if the \nreturn position has a reasonable \nbasis. It can also be used for \ndisclosures relating to the economic \nsubstance penalty and the preparer \npenalties for tax understatements due \nto positions taken contrary to \nregulations.\nThe portion of the \naccuracy-related penalty \nattributable to the following \ntypes of misconduct cannot be \navoided by disclosure on Form \n8275-R.\n• Negligence.\n• Disregard of rules.\n• Any substantial understatement of \nincome tax on a tax shelter item.\n• Any substantial or gross valuation \nmisstatement (including \nmisstatements attributable to \nnon-arm's length prices) under \nchapter 1.\n• Any substantial overstatement of \npension liabilities.\n• Any substantial estate or gift tax \nvaluation understatements.\n• Any claim of tax benefits from a \ntransaction lacking economic \nCAUTION\n!\nsubstance (within the meaning of \nsection 7701(o)) or failing to meet the \nrequirements of any similar rule of \nlaw.\n• Any otherwise undisclosed foreign \nfinancial asset understatement.\nBecause of the importance to the \nself-assessment system of disclosing \npositions contrary to regulations, the \nrequirements for making such \ndisclosures are stringent.\n• The disclosure is adequate only if it \nis made separately on a Form \n8275-R.\n• The penalty for reckless or \nintentional disregard of a regulation \ncan be avoided by disclosure only if \nthe position represents a good-faith \nchallenge to the validity of the \nregulation and has a reasonable \nbasis.\nInstead of Form 8275-R, use Form \n8275, Disclosure Statement, for the \ndisclosure of items or positions which \nare not contrary to regulations but \nwhich are not otherwise adequately \ndisclosed.\nWho Should File\nForm 8275-R is filed by individuals, \ncorporations, pass-through entities, \nand tax return preparers.\nFor items attributable to a \npass-through entity, disclosure should \nbe made on the tax return of the \nentity. If the entity does not make the \ndisclosure, the partner (or \nshareholder, etc.) can make adequate \ndisclosure of these items.\nHow To File\nWhen a return position is contrary to \nregulations, you must file Form \n8275-R. File all Forms 8275-R with \nyour original tax return. Keep a copy \nfor your records. You may also be \nable to file Forms 8275-R with an \namended return. See Regulations \nsections 1.6662-4(f)(1) and \n1.6664-2(c)(3) for more information.\nTo make adequate disclosure for \nitems reported by a pass-through \nentity, you must complete and file a \nseparate Form 8275-R for items \nreported by each entity.\nTo make adequate disclosure for a \nposition or positions related to more \nthan one foreign entity, you must \ncomplete and file a separate Form \n8275-R for each foreign entity.\nCarryovers, carrybacks, and recur-\nring items. Carryover items must be \ndisclosed in the tax year in which they \noriginated. You do not have to file \nanother Form 8275-R for those items \nfor the tax years in which the \ncarryover is taken into account.\nCarryback items must be disclosed \nfor the tax year in which they \noriginated. You do not have to file \nanother Form 8275-R for those items \nfor the tax years in which the \ncarryback is taken into account.\nHowever, if you disclose items that \nare of a recurring nature (such as \ndepreciation expense), you must file \nForm 8275-R for each tax year in \nwhich the item occurs.\nIf you are disclosing a position that \nis contrary to a regulation, and the \nposition relates to a reportable \ntransaction as defined in Regulations \nsection 1.6011-4(b), you must also \nmake the disclosure as indicated in \nRegulations section 1.6011-4(d). See \nForm 8886, Reportable Transaction \nDisclosure Statement, and its \ninstructions; Notice 2006-6, 2006-5 \nI.R.B. 385, available at IRS.gov/irb/\n2006-05_IRB/ar10.html; and Notice \n2010-62, 2010-40 I.R.B. 411, \navailable at IRS.gov/irb/2010-40_IRB/\nar09.html.\nAccuracy-Related Penalty\nGenerally, the accuracy-related \npenalty is 20% of any portion of a tax \nunderpayment attributable to:\n1. Negligence or disregard of rules \nor regulations;\nOct 06, 2020\nCat. No. 14317I\n", "2. Any substantial understatement \nof income tax;\n3. Any substantial valuation \nmisstatement under chapter 1 of the \nInternal Revenue Code;\n4. Any substantial overstatement \nof pension liabilities;\n5. Any substantial estate or gift tax \nvaluation understatement; or\n6. Any claim of tax benefits from a \ntransaction lacking economic \nsubstance, as defined by section \n7701(o), or failing to meet the \nrequirements of any similar rule of \nlaw.\nThe penalty is 40% of any portion \nof a tax underpayment attributable to \none or more gross valuation \nmisstatements in (3), (4), or (5) above \nif the applicable dollar limitation under \nsection 6662(h)(2) is met. The penalty \nalso increases to 40% for failing to \nadequately disclose a transaction that \nlacks economic substance in (6) \nabove. See Economic substance, \nbelow. The penalty is 40% of any \nportion of an underpayment that is \nattributable to any undisclosed foreign \nfinancial asset understatement.\nEconomic substance. To satisfy the \ndisclosure requirements under section \n6662(i), you may adequately disclose \nwith a timely filed original return \n(determined with regard to \nextensions) or a qualified amended \nreturn (as defined under Regulations \nsection 1.6664-2(c)(3)) the relevant \nfacts affecting the tax treatment of the \ntransaction.\nNote. If you filed a Schedule UTP \n(Form 1120), you may not need to file \nForm 8275-R to satisfy the disclosure \nrequirements of section 6662(i). See \nthe Instructions for Schedule UTP \n(Form 1120).\nReasonable cause exception. \nGenerally, no accuracy-related \npenalty will be imposed on any portion \nof an underpayment if you show that \nthere was reasonable cause for that \nportion and that you acted in good \nfaith with respect to that portion.\nThe reasonable cause and \ngood faith exception does not \napply to any portion of an \nunderpayment attributable to a \ntransaction that lacks economic \nsubstance under section 7701(o).\nCAUTION\n!\nIf you failed to keep proper books \nand records or failed to substantiate \nitems properly, you cannot avoid the \npenalty by disclosure.\nAdequate disclosure. Generally, \nyou can avoid the disregard of \nregulations and substantial \nunderstatement portions of the \naccuracy-related penalty if the \nposition is adequately disclosed and \nthe position has at least a reasonable \nbasis. To avoid the disregard of \nregulations portion of the \naccuracy-related penalty, the position \ntaken must also represent a \ngood-faith challenge to the validity of \nthe regulation. See Regulations \nsection 1.6662-3(c)(1).\nReasonable basis. Reasonable \nbasis is a relatively high standard of \ntax reporting that is significantly higher \nthan not frivolous or not patently \nimproper. The reasonable basis \nstandard is not satisfied by a return \nposition that is merely arguable.\nIf the return position is reasonably \nbased on one of the authorities set \nforth in Regulations section \n1.6662-4(d)(3)(iii) (taking into account \nthe relevance and persuasiveness of \nthe authorities, and subsequent \ndevelopments), the return position will \ngenerally satisfy the reasonable basis \nstandard even though it may not \nsatisfy the substantial authority \nstandard as defined in Regulations \nsection 1.6662-4(d)(2). For details, \nsee Regulations sections 1.6662-4(d); \n1.662-3(b)(3).\nIf you failed to keep proper books \nand records or failed to substantiate \nitems properly, you cannot avoid the \npenalty by disclosure.\nSubstantial Understatement\nAn understatement is the excess of:\n1. The amount of tax required to \nbe shown on the return for the tax \nyear, over\n2. The amount of tax shown on the \nreturn for the tax year, reduced by any \nrebates.\nThere is a substantial \nunderstatement of income tax if the \namount of the understatement for any \nyear exceeds the greater of:\n1. 10% of the tax required to be \nshown on the return for the tax year, \nor\n2. $5,000.\nAn understatement of a corporation \n(other than an S corporation or a \npersonal holding company, as defined \nin section 542) is substantial if it \nexceeds in any year the lesser of:\n1. 10% of the tax required to be \nshown on the return for the tax year \n(or, if greater, $10,000), or\n2. $10,000,000.\nReduction of understatement. The \namount of the understatement will be \nreduced by the part that is attributable \nto the following items.\n• An item (other than a tax shelter \nitem) for which there was substantial \nauthority for the treatment claimed at \nthe time the return was filed or on the \nlast day of the tax year to which the \nreturn relates.\n• An item (other than a tax shelter \nitem) that is adequately disclosed on \nthis form if there is a reasonable basis \nfor the tax treatment of the item. (In no \nevent will a corporation be treated as \nhaving a reasonable basis for its tax \ntreatment of an item attributable to a \nmulti-party financing transaction \nentered into after August 5, 1997, if \nthe treatment does not clearly reflect \nthe income of the corporation.\nFor corporate tax shelter \ntransactions (and for tax shelter items \nof other taxpayers for tax years \nending after October 22, 2004), the \nonly exception to the substantial \nunderstatement portion of the \naccuracy-related penalty is the \nreasonable cause exception. For \nmore details, see Reasonable cause \nexception, earlier; section 6662(d); \nand Regulations section 1.6664-4.\nTax shelter items. A tax shelter, \nfor purposes of the substantial \nunderstatement portion of the \naccuracy-related penalty, is a \npartnership or other entity, plan, or \narrangement, with a significant \npurpose to avoid or evade federal \nincome tax. For transactions on or \nbefore August 5, 1997, a tax shelter is \na partnership or other entity, plan, or \narrangement, whose principal \npurpose is to avoid or evade federal \nincome tax.\nA tax shelter item is any item of \nincome, gain, loss, deduction, or \ncredit that is directly or indirectly \nattributable to the principal or \nsignificant purpose of the tax shelter \nto avoid or evade federal income tax.\n-2-\n", "Tax Return Preparer Penalties\nA preparer who files a return or claim \nfor refund is subject to a penalty in an \namount equal to the greater of $1,000 \nor 50% of the income derived (or to be \nderived) by the tax return preparer, \nwith respect to the return or claim, for \ntaking a position which the preparer \nknew or reasonably should have \nknown would understate any part of \nthe liability if:\n• There is or was no substantial \nauthority for the position;\n• The position is a tax shelter (as \ndefined in section 6662(d)(2)(C)(ii)) or \na reportable transaction to which \nsection 6662A applies and it was not \nreasonable to believe that the position \nwould more likely than not be \nsustained on its merits; or\n• The position disclosed as provided \nin section 6662(d)(2)(B)(ii) is not a tax \nshelter or a reportable transaction to \nwhich section 6662A applies, and \nthere was no reasonable basis for the \nposition.\nThe penalty will not apply if it can \nbe shown that there was reasonable \ncause for the understatement and that \nthe preparer acted in good faith.\nIn cases where any part of the \nunderstatement of the liability is due \nto a willful attempt by the return \npreparer to understate the liability, or \nif the understatement is due to \nreckless or intentional disregard of \nrules or regulations by the preparer, \nthe preparer is subject to a penalty \nequal to the greater of $5,000 or 75% \nof the income derived (or to be \nderived) by the tax return preparer \nwith respect to the return or claim. \nThis penalty shall be reduced by the \namount of the penalty paid by such \nperson for taking an unreasonable \nposition, or a position with no \nreasonable basis, as described \nimmediately above.\nA preparer is not considered to \nhave recklessly or intentionally \ndisregarded a rule if a position is \nadequately disclosed and has a \nreasonable basis.\nNote. For more information about the \naccuracy-related penalty and preparer \npenalties, and the means of avoiding \nthese penalties, see the regulations \nunder sections 6662, 6664, and 6694.\nSpecific Instructions\nBe sure to supply all of the information \nrequested in Parts I and II and, if \napplicable, Part III. Your disclosure \nwill be considered adequate if you file \nForm 8275-R and supply the \ninformation requested in detail.\nUse Part IV on page 2 if you need \nmore space for Part I or II. Indicate the \ncorresponding part and line number \nfrom page 1. You can use a \ncontinuation sheet(s) if you need \nadditional space. Be sure to put your \nname and identifying number on each \nsheet.\nReference ID number. If you are \nfiling Form 8275-R to disclose a \nposition related to a foreign entity for \nwhich an information return (such as \nForm 5471) is filed, enter on Form \n8275-R the same reference ID \nnumber for the foreign entity that is \nentered on the information return.\nIf you are filing Form 8275-R to \nreport a position or positions related to \nmultiple foreign entities, file a \nseparate Form 8275-R for each \nforeign entity.\nPart I\nColumn (a). Enter the full citation for \neach regulation for which you have \ntaken a contrary position. The citation \nshould specify the section number, \nincluding all designations of smaller \nunits (lettered or numbered \nsubsections, paragraphs, \nsubparagraphs, and clauses) to which \nthe contrary position relates. For \nexample, enter “1.482-7(d)(1)(iii)” \ninstead of “482 regs” or “1.482-7”.\nColumn (b). Identify the item by \nname.\nIf any item you disclose is from a \npass-through entity, you must identify \nthe item as such. If you disclose items \nfrom more than one pass-through \nentity, you must complete a separate \nForm 8275-R for each entity. Also, \nsee How To File, earlier.\nColumn (c). Enter a complete \ndescription of the item(s) you are \ndisclosing.\nExample. If an entertainment \nexpense was reported in column (b), \nthen list in column (c) “theater tickets, \ncatering expenses, and banquet hall \nrentals.”\nIf you claim the same tax treatment \nfor a group of similar items in the \nsame tax year, enter a description \nidentifying the group of items you are \ndisclosing rather than a separate \ndescription of each item within the \ngroup.\nColumns (d) through (f). Enter the \nlocation of the item(s) by identifying \nthe form number or schedule and the \nline number in columns (d) and (e) \nand the amount of the item(s) in \ncolumn (f).\nPart II\nYour disclosure must include the \nfollowing.\n1. A description of the relevant \nfacts affecting the tax treatment of the \nitem. To satisfy this requirement, you \nmust include information that can \nreasonably be expected to apprise the \nIRS of the identity of the item, its \namount, and the nature of the \ncontroversy or potential controversy. \nInformation concerning the nature of \nthe controversy can include a \ndescription of the legal issues \npresented by the facts.\n2. A statement explaining why you \nbelieve this regulation to be invalid.\nUnless provided otherwise in \nthe General Instructions, \nearlier, your disclosure will not \nbe considered adequate unless (1) \nand (2) above are provided using \nForm 8275-R. For example, your \ndisclosure will not be considered \nadequate if you attach a copy of an \nacquisition agreement to your tax \nreturn to disclose the issues involved \nin determining the basis of certain \nacquired assets. If Form 8275-R is not \ncompleted and attached to the return, \nthe disclosure will not be considered \nvalid even if the information in (1) and \n(2) above is provided using another \nmethod, such as a different form or an \nattached letter.\nPart III\nLine 4. Contact your pass-through \nentity if you do not know where its \nreturn was filed. However, for partners \nand S corporation shareholders, \ninformation for line 4 can be found on \nthe Schedule K-1 that you received \nfrom the partnership or S corporation.\nCAUTION\n!\n-3-\n", "If the pass-through entity filed its \nreturn electronically using e-file, enter \n“e-file” on line 4.\nPaperwork Reduction Act Notice. \nWe ask for the information on this \nform to carry out the Internal Revenue \nlaws of the United States. You are \nrequired to give us the information if \nyou wish to use this form to make \nadequate disclosure to avoid the \nportion of the accuracy-related \npenalty due to a substantial \nunderstatement of income tax or \ndisregard of regulations, or to avoid \ncertain preparer penalties. We need it \nto ensure that you are complying with \nthese laws and to allow us to figure \nand collect the right amount of tax.\nYou are not required to provide the \ninformation requested on a form that \nis subject to the Paperwork Reduction \nAct unless the form displays a valid \nOMB control number. Books or \nrecords relating to a form or its \ninstructions must be retained as long \nas their contents may become \nmaterial in the administration of any \nInternal Revenue law. Generally, tax \nreturns and return information are \nconfidential, as required by section \n6103.\nThe time needed to complete and \nfile this form will vary depending on \nindividual circumstances. The \nestimated burden for individual \ntaxpayers filing this form is approved \nunder OMB control number \n1545-0074 and is included in the \nestimates shown in the instructions for \ntheir individual income tax return. The \nestimated burden for all other \ntaxpayers who file this form is shown \nbelow.\nRecordkeeping. . . . . .\n3 hr., 35 min.\nLearning about the \nlaw or the form . . . .\n53 min.\nPreparing and sending \nthe form to the IRS .\n59 min.\nIf you have comments concerning \nthe accuracy of these time estimates \nor suggestions for making this form \nsimpler, we would be happy to hear \nfrom you. See the instructions for the \ntax return with which this form is filed.\n-4-\n" ]
f8994.pdf	0121 Form 8994 (PDF)	https://www.irs.gov/pub/irs-pdf/f8994.pdf	[ "Form 8994\n(Rev. January 2021)\nEmployer Credit for Paid Family and Medical Leave\nDepartment of the Treasury \nInternal Revenue Service \n▶ Attach to your tax return. \n▶ Go to www.irs.gov/Form8994 for instructions and the latest information.\nOMB No. 1545-2282\nAttachment \nSequence No. 994\nName(s) shown on return \nIdentifying number \nA \nDo you have a written policy providing for at least 2 weeks of annual paid family and medical leave for your qualifying \nemployee(s) to whom wages are paid (prorated for any part-time employees)? See instructions.\nYes. \nNo. Stop. Do not file Form 8994 (see instructions for an exception that may apply to a partnership or S corporation).\nB \nDoes the written policy provide paid family and medical leave of at least 50% of the wages normally paid to a qualifying \nemployee? See instructions.\nYes. \nNo. Stop. Do not file Form 8994 (see instructions for an exception that may apply to a partnership or S corporation).\nC\nDid you pay family and medical leave to at least one qualifying employee during the tax year? See instructions.\nYes. \nNo. Stop. Do not file Form 8994 (see instructions for an exception that may apply to a partnership or S corporation).\nD \nIf you employed at least one qualifying employee who was not covered by the Family and Medical Leave Act, did you include\nin your written policy and otherwise comply with “non-interference” language? See instructions.\nYes. \nNo. Stop. Do not file Form 8994 (see instructions for an exception that may apply to a partnership or S corporation).\n1 \n \n \nEnter the total paid family and medical leave credit figured for wages paid during your tax year to your \nqualifying employee(s) while on family and medical leave (if you use the Paid Family and Medical\nLeave Credit Worksheet, the total from column (d)). See instructions for the adjustment you must \nmake to your deduction for salaries and wages \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. \n1\n2\nEmployer credit for paid family and medical leave from partnerships and S corporations (see instructions) \n2\n3 \nAdd lines 1 and 2. Partnerships and S corporations, report this amount on Schedule K. All others, \nreport this amount on Form 3800, Part III, line 4j .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. \n3\nFor Paperwork Reduction Act Notice, see separate instructions. \nCat. No. 37804G\nForm 8994 (Rev. 1-2021)\n" ]
f2848.pdf	0121 Form 2848 (PDF)	https://www.irs.gov/pub/irs-pdf/f2848.pdf	[ "Form 2848\n(Rev. January 2021) \nDepartment of the Treasury \nInternal Revenue Service \nPower of Attorney \nand Declaration of Representative \n ▶ Go to www.irs.gov/Form2848 for instructions and the latest information.\nOMB No. 1545-0150 \nFor IRS Use Only \nReceived by: \nName \nTelephone \nFunction \nDate / / \nPart I \nPower of Attorney \n \nCaution: A separate Form 2848 must be completed for each taxpayer. Form 2848 will not be honored \nfor any purpose other than representation before the IRS. \n1\nTaxpayer information. Taxpayer must sign and date this form on page 2, line 7. \nTaxpayer name and address \nTaxpayer identification number(s) \nDaytime telephone number \nPlan number (if applicable) \nhereby appoints the following representative(s) as attorney(s)-in-fact: \n2\nRepresentative(s) must sign and date this form on page 2, Part II. \nName and address\nCheck if to be sent copies of notices and communications\nCAF No. \nPTIN\nTelephone No. \nFax No. \nCheck if new: Address \nTelephone No. \nFax No. \nName and address\nCheck if to be sent copies of notices and communications\nCAF No. \nPTIN\nTelephone No. \nFax No. \nCheck if new: Address \nTelephone No. \nFax No. \nName and address\n(Note: IRS sends notices and communications to only two representatives.)\nCAF No. \nPTIN\nTelephone No. \nFax No. \nCheck if new: Address \nTelephone No. \nFax No. \nName and address\n(Note: IRS sends notices and communications to only two representatives.)\nCAF No. \nPTIN\nTelephone No. \nFax No. \nCheck if new: Address \nTelephone No. \nFax No. \nto represent the taxpayer before the Internal Revenue Service and perform the following acts:\n3 \n \n \n \nActs authorized (you are required to complete line 3). Except for the acts described in line 5b, I authorize my representative(s) to receive and \ninspect my confidential tax information and to perform acts I can perform with respect to the tax matters described below. For example, my \nrepresentative(s) shall have the authority to sign any agreements, consents, or similar documents (see instructions for line 5a for authorizing a \nrepresentative to sign a return).\nDescription of Matter (Income, Employment, Payroll, Excise, Estate, Gift, \nWhistleblower, Practitioner Discipline, PLR, FOIA, Civil Penalty, Sec. \n4980H Shared Responsibility Payment, etc.) (see instructions) \nTax Form Number \n(1040, 941, 720, etc.) (if applicable) \nYear(s) or Period(s) (if applicable) \n(see instructions) \n4 \n \nSpecific use not recorded on the Centralized Authorization File (CAF). If the power of attorney is for a specific use not recorded on \nCAF, check this box. See Line 4. Specific Use Not Recorded on CAF in the instructions .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\n5 \n \na \n \nAdditional acts authorized. In addition to the acts listed on line 3 above, I authorize my representative(s) to perform the following acts (see \ninstructions for line 5a for more information):\nAccess my IRS records via an Intermediate Service Provider;\nAuthorize disclosure to third parties;\nSubstitute or add representative(s);\nSign a return;\nOther acts authorized:\nFor Privacy Act and Paperwork Reduction Act Notice, see the instructions. \nCat. No. 11980J \nForm 2848 (Rev. 1-2021) \nCheck Form for Common Errors & Reminders\n", "Form 2848 (Rev. 1-2021)\nPage 2 \nb \n \n \nSpecific acts not authorized. My representative(s) is (are) not authorized to endorse or otherwise negotiate any check (including directing or \naccepting payment by any means, electronic or otherwise, into an account owned or controlled by the representative(s) or any firm or other \nentity with whom the representative(s) is (are) associated) issued by the government in respect of a federal tax liability.\nList any other specific deletions to the acts otherwise authorized in this power of attorney (see instructions for line 5b): \n6 \n \n \nRetention/revocation of prior power(s) of attorney. The filing of this power of attorney automatically revokes all earlier power(s) of \nattorney on file with the Internal Revenue Service for the same matters and years or periods covered by this form. If you do not want to \nrevoke a prior power of attorney, check here .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nYOU MUST ATTACH A COPY OF ANY POWER OF ATTORNEY YOU WANT TO REMAIN IN EFFECT. \n7 \n \n \n \nTaxpayer declaration and signature. If a tax matter concerns a year in which a joint return was filed, each spouse must file a separate power \nof attorney even if they are appointing the same representative(s). If signed by a corporate officer, partner, guardian, tax matters partner, \npartnership representative (or designated individual, if applicable), executor, receiver, administrator, trustee, or individual other than the \ntaxpayer, I certify I have the legal authority to execute this form on behalf of the taxpayer. \n▶ IF NOT COMPLETED, SIGNED, AND DATED, THE IRS WILL RETURN THIS POWER OF ATTORNEY TO THE TAXPAYER. \nSignature \nDate \nTitle (if applicable) \nPrint name\nPrint name of taxpayer from line 1 if other than individual \nPart II \nDeclaration of Representative \n Under penalties of perjury, by my signature below I declare that: \n• I am not currently suspended or disbarred from practice, or ineligible for practice, before the Internal Revenue Service;\n• I am subject to regulations in Circular 230 (31 CFR, Subtitle A, Part 10), as amended, governing practice before the Internal Revenue Service;\n• I am authorized to represent the taxpayer identified in Part I for the matter(s) specified there; and \n• I am one of the following: \na Attorney—a member in good standing of the bar of the highest court of the jurisdiction shown below. \nb Certified Public Accountant—a holder of an active license to practice as a certified public accountant in the jurisdiction shown below. \nc Enrolled Agent—enrolled as an agent by the IRS per the requirements of Circular 230. \nd Officer—a bona fide officer of the taxpayer organization. \ne Full-Time Employee—a full-time employee of the taxpayer. \nf Family Member—a member of the taxpayer’s immediate family (spouse, parent, child, grandparent, grandchild, step-parent, step-child, brother, or sister).\ng Enrolled Actuary—enrolled as an actuary by the Joint Board for the Enrollment of Actuaries under 29 U.S.C. 1242 (the authority to practice before \nthe IRS is limited by section 10.3(d) of Circular 230). \nh Unenrolled Return Preparer—Authority to practice before the IRS is limited. An unenrolled return preparer may represent, provided the preparer (1) \nprepared and signed the return or claim for refund (or prepared if there is no signature space on the form); (2) was eligible to sign the return or \nclaim for refund; (3) has a valid PTIN; and (4) possesses the required Annual Filing Season Program Record of Completion(s). See Special Rules \nand Requirements for Unenrolled Return Preparers in the instructions for additional information.\nk Qualifying Student or Law Graduate—receives permission to represent taxpayers before the IRS by virtue of his/her status as a law, business, or \naccounting student, or law graduate working in a LITC or STCP. See instructions for Part II for additional information and requirements.\nr Enrolled Retirement Plan Agent—enrolled as a retirement plan agent under the requirements of Circular 230 (the authority to practice before the \nInternal Revenue Service is limited by section 10.3(e)). \n▶ IF THIS DECLARATION OF REPRESENTATIVE IS NOT COMPLETED, SIGNED, AND DATED, THE IRS WILL RETURN THE \nPOWER OF ATTORNEY. REPRESENTATIVES MUST SIGN IN THE ORDER LISTED IN PART I, LINE 2. \nNote: For designations d–f, enter your title, position, or relationship to the taxpayer in the “Licensing jurisdiction” column.\nDesignation—\nInsert above \nletter (a–r).\nLicensing jurisdiction \n(State) or other \nlicensing authority \n(if applicable)\nBar, license, certification, \nregistration, or enrollment \nnumber (if applicable)\nSignature \nDate \nForm 2848 (Rev. 1-2021) \n" ]
f8879.pdf	0121 Form 8879 (PDF)	https://www.irs.gov/pub/irs-pdf/f8879.pdf	[ "Form 8879\n(Rev. January 2021)\nDepartment of the Treasury \nInternal Revenue Service\nIRS e-file Signature Authorization\n▶ ERO must obtain and retain completed Form 8879. \n▶ Go to www.irs.gov/Form8879 for the latest information.\nOMB No. 1545-0074\nSubmission Identification Number (SID)\n▲\nTaxpayer’s name\nSocial security number\nSpouse’s name\nSpouse’s social security number\nPart I \nTax Return Information — Tax Year Ending December 31,\n(Enter year you are authorizing.)\nEnter whole dollars only on lines 1 through 5.\nNote: Form 1040-SS filers use line 4 only. Leave lines 1, 2, 3, and 5 blank.\n1\nAdjusted gross income \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n1\n2\nTotal tax\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2\n3\nFederal income tax withheld from Form(s) W-2 and Form(s) 1099 .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n3\n4\nAmount you want refunded to you \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4\n5\nAmount you owe\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n5\nPart II\nTaxpayer Declaration and Signature Authorization (Be sure you get and keep a copy of your return)\nUnder penalties of perjury, I declare that I have examined a copy of the income tax return (original or amended) I am now authorizing, and to the best of \nmy knowledge and belief, it is true, correct, and complete. I further declare that the amounts in Part I above are the amounts from the income tax \nreturn (original or amended) I am now authorizing. I consent to allow my intermediate service provider, transmitter, or electronic return originator (ERO) \nto send my return to the IRS and to receive from the IRS (a) an acknowledgement of receipt or reason for rejection of the transmission, (b) the reason \nfor any delay in processing the return or refund, and (c) the date of any refund. If applicable, I authorize the U.S. Treasury and its designated Financial \nAgent to initiate an ACH electronic funds withdrawal (direct debit) entry to the financial institution account indicated in the tax preparation software for \npayment of my federal taxes owed on this return and/or a payment of estimated tax, and the financial institution to debit the entry to this account. This \nauthorization is to remain in full force and effect until I notify the U.S. Treasury Financial Agent to terminate the authorization. To revoke (cancel) a \npayment, I must contact the U.S. Treasury Financial Agent at 1-888-353-4537. Payment cancellation requests must be received no later than 2 \nbusiness days prior to the payment (settlement) date. I also authorize the financial institutions involved in the processing of the electronic payment of \ntaxes to receive confidential information necessary to answer inquiries and resolve issues related to the payment. I further acknowledge that the \npersonal identification number (PIN) below is my signature for the income tax return (original or amended) I am now authorizing and, if applicable, my \nElectronic Funds Withdrawal Consent.\nTaxpayer’s PIN: check one box only\nI authorize \nERO firm name\nto enter or generate my PIN \nEnter five digits, but \ndon’t enter all zeros\nas my\nsignature on the income tax return (original or amended) I am now authorizing.\nI will enter my PIN as my signature on the income tax return (original or amended) I am now authorizing. Check this box only \nif you are entering your own PIN and your return is filed using the Practitioner PIN method. The ERO must complete Part III \nbelow.\nYour signature ▶\nDate ▶\nSpouse’s PIN: check one box only\nI authorize \nERO firm name\nto enter or generate my PIN \nEnter five digits, but \ndon’t enter all zeros\nas my\nsignature on the income tax return (original or amended) I am now authorizing.\nI will enter my PIN as my signature on the income tax return (original or amended) I am now authorizing. Check this box only \nif you are entering your own PIN and your return is filed using the Practitioner PIN method. The ERO must complete Part III \nbelow.\nSpouse’s signature ▶\nDate ▶\nPractitioner PIN Method Returns Only—continue below\nPart III\nCertification and Authentication — Practitioner PIN Method Only\nERO’s EFIN/PIN. Enter your six-digit EFIN followed by your five-digit self-selected PIN.\nDon’t enter all zeros\nI certify that the above numeric entry is my PIN, which is my signature for the electronic individual income tax return (original or amended) I am now \nauthorized to file for tax year indicated above for the taxpayer(s) indicated above. I confirm that I am submitting this return in accordance with the \nrequirements of the Practitioner PIN method and Pub. 1345, Handbook for Authorized IRS e-file Providers of Individual Income Tax Returns.\nERO’s signature ▶\nDate ▶\nERO Must Retain This Form — See Instructions \nDon’t Submit This Form to the IRS Unless Requested To Do So\nFor Paperwork Reduction Act Notice, see your tax return instructions.\nCat. No. 32778X\nForm 8879 (Rev. 01-2021)\n", "Form 8879 (Rev. 01-2021)\nPage 2\nGeneral Instructions\nSection references are to the Internal Revenue \nCode unless otherwise noted.\nFuture developments. For the latest \ninformation about developments related to \nForm 8879 and its instructions, such as \nlegislation enacted after they were published, \ngo to www.irs.gov/Form8879. \nWhat's New. Form 8879 is used to authorize \nthe electronic filing (e-file) of original and \namended returns. Use this Form 8879 (Rev. \nJanuary 2021) to authorize e-file of your Form \n1040, 1040-SR, 1040-NR, 1040-SS, or 1040-\nX, for tax years beginning with 2019.\nPurpose of Form\nForm 8879 is the declaration document and \nsignature authorization for an e-filed return \nfiled by an electronic return originator (ERO). \nComplete Form 8879 when the Practitioner \nPIN method is used or when the taxpayer \nauthorizes the ERO to enter or generate the \ntaxpayer’s personal identification number \n(PIN) on his or her e-filed individual income \ntax return.\n▲\n!\nCAUTION\nDon’t send this form to the IRS. \nThe ERO must retain Form 8879.\nWhen and How To Complete\nUse this chart to determine when and how to \ncomplete Form 8879.\nIF the ERO is . . .\nTHEN . . .\nNot using the Practitioner \nPIN method and the \ntaxpayer enters his or her \nown PIN\nDon’t complete \nForm 8879.\nNot using the Practitioner \nPIN method and is \nauthorized to enter or \ngenerate the taxpayer’s \nPIN\nComplete Form \n8879, Parts I and II.\nUsing the Practitioner PIN \nmethod and is authorized \nto enter or generate the \ntaxpayer’s PIN\nComplete Form 8879, \nParts I, II, and III.\nUsing the Practitioner PIN \nmethod and the taxpayer \nenters his or her own PIN\nComplete Form 8879, \nParts I, II, and III.\nERO Responsibilities\nThe ERO must:\n1. Enter the name(s) and social security \nnumber(s) of the taxpayer(s) at the top of the \nform.\n2. Complete Part I using the amounts (zeros \nmay be entered when appropriate) from the \ntaxpayer’s tax return. Form 1040-SS filers \nleave lines 1 through 3 and line 5 blank.\n3. Enter or generate, if authorized by the \ntaxpayer, the taxpayer’s PIN and enter it in \nthe boxes provided in Part II.\n4. Enter on the authorization line in Part II \nthe ERO firm name (not the name of the \nindividual preparing the return) if the ERO is \nauthorized to enter the taxpayer’s PIN.\n5. Provide the taxpayer(s) Form 8879 by \nhand delivery, U.S. mail, private delivery \nservice, email, Internet website, or fax.\n6. Enter the 20-digit Submission Identification \nNumber (SID) assigned to the tax return, or \nassociate Form 9325, Acknowledgement and \nGeneral Information for Taxpayers Who File \nReturns Electronically, with Form 8879 after \nfiling. If Form 9325 is used to provide the SID, it \nisn’t required to be physically attached to Form \n8879. However, it must be kept in accordance \nwith published retention requirements for Form \n8879. See Pub. 4164, Modernized e-File (MeF) \nGuide for Software Developers and \nTransmitters, for more details.\n▲\n!\nCAUTION\nYou must receive the completed \nand signed Form 8879 from the \ntaxpayer before the electronic \nreturn is transmitted (or released \nfor transmission).\nFor additional information, see Pub. 1345.\nTaxpayer Responsibilities\nTaxpayers must:\n1. Verify the accuracy of the prepared income \ntax return, including direct deposit information.\n2. Check the appropriate box in Part II to \nauthorize the ERO to enter or generate your \nPIN or to do it yourself.\n3. Indicate or verify your PIN when \nauthorizing the ERO to enter or generate it (the \nPIN must be five digits other than all zeros).\n4. Sign and date Form 8879. Taxpayers \nmust sign Form 8879 by handwritten \nsignature, or electronic signature if supported \nby computer software. \n5. Return the completed Form 8879 to the \nERO by hand delivery, U.S. mail, private \ndelivery service, email, Internet website, or fax.\nYour return won’t be transmitted to the IRS \nuntil the ERO receives your signed Form 8879.\nRefund information. You can check on the \nstatus of your refund if it has been at least 72 \nhours since the IRS acknowledged receipt of \nyour e-filed return. But if you filed Form 8379 \nwith your return, allow 11 weeks. To check \nthe status of your refund, do one of the \nfollowing.\n• Go to www.irs.gov/Refunds.\n• Call 1-800-829-4477 for automated refund \ninformation and follow the recorded \ninstructions.\n• Call 1-800-829-1954.\nImportant Notes for EROs\n• Don’t send Form 8879 to the IRS unless \nrequested to do so. Retain the completed \nForm 8879 for 3 years from the return due \ndate or IRS received date, whichever is later. \nForm 8879 may be retained electronically in \naccordance with the recordkeeping guidelines \nin Rev. Proc. 97-22, which is on page 9 of \nInternal Revenue Bulletin 1997-13 at \nwww.irs.gov/pub/irs-irbs/irb97-13.pdf.\n• Confirm the identity of the taxpayer(s). \n• Complete Part III only if you are filing the \nreturn using the Practitioner PIN method. You \naren’t required to enter the taxpayer’s date of \nbirth, prior year adjusted gross income, or PIN \nin the Authentication Record of the \nelectronically filed return.\n• If you aren’t using the Practitioner PIN \nmethod, enter the taxpayer(s) date of birth \nand either the adjusted gross income or the \nPIN, or both, from the taxpayer’s prior year \noriginally filed return in the Authentication \nRecord of the taxpayer’s electronically filed \nreturn. Don’t use an amount from an \namended return or a math error correction \nmade by the IRS.\n• Enter the taxpayer’s PIN(s) on the input \nscreen only if the taxpayer has authorized you \nto do so. If married filing jointly, it is \nacceptable for one spouse to authorize you to \nenter his or her PIN, and for the other spouse \nto enter his or her own PIN. It isn’t acceptable \nfor a taxpayer to select or enter the PIN of an \nabsent spouse.\n• Taxpayers must use a PIN to sign their \ne-filed individual income tax return \ntransmitted by an ERO.\n• Provide the taxpayer with a copy of the \nsigned Form 8879 for his or her records upon \nrequest.\n• Provide the taxpayer with a corrected copy \nof Form 8879 if changes are made to the \nreturn (for example, based on taxpayer \nreview).\n• EROs can sign the form using a rubber \nstamp, mechanical device (such as a \nsignature pen), or computer software \nprogram. See Notice 2007-79, 2007-42 I.R.B. \n809, available at www.irs.gov/\nirb/2007-42_IRB/ar10.html, for more \ninformation.\n• Go to www.irs.gov/Efile for the latest \ninformation. \n" ]
f8821.pdf	0121 Form 8821 (PDF)	https://www.irs.gov/pub/irs-pdf/f8821.pdf	[ "Form 8821 \n(Rev. January 2021) \nTax Information Authorization \nDepartment of the Treasury \nInternal Revenue Service \n▶ Go to www.irs.gov/Form8821 for instructions and the latest information.\n▶ Don’t sign this form unless all applicable lines have been completed. \n▶ Don’t use Form 8821 to request copies of your tax returns \nor to authorize someone to represent you. See instructions.\nOMB No. 1545-1165 \nFor IRS Use Only \nReceived by: \nName \nTelephone\nFunction\nDate\n1 Taxpayer information. Taxpayer must sign and date this form on line 6. \nTaxpayer name and address\nTaxpayer identification number(s)\nDaytime telephone number Plan number (if applicable) \n2 \n \nDesignee(s). If you wish to name more than two designees, attach a list to this form. Check here if a list of additional \ndesignees is attached ▶ \nName and address \nCheck if to be sent copies of notices and communications\nCAF No. \nPTIN \nTelephone No. \nFax No. \nCheck if new: Address \nTelephone No. \nFax No. \nName and address \nCheck if to be sent copies of notices and communications\nCAF No. \nPTIN \nTelephone No. \nFax No. \nCheck if new: Address \nTelephone No. \nFax No. \n3 Tax information. Each designee is authorized to inspect and/or receive confidential tax information for the type of tax, forms, \nperiods, and specific matters you list below. See the line 3 instructions. \nBy checking here, I authorize access to my IRS records via an Intermediate Service Provider.\n(a) \nType of Tax Information (Income, \nEmployment, Payroll, Excise, Estate, Gift, \nCivil Penalty, Sec. 4980H Payments, etc.) \n(b) \nTax Form Number \n(1040, 941, 720, etc.)\n(c) \nYear(s) or Period(s)\n(d) \nSpecific Tax Matters\n4 Specific use not recorded on the Centralized Authorization File (CAF). If the tax information authorization is for a \nspecific use not recorded on CAF, check this box. See the instructions. If you check this box, skip line 5 .\n.\n.\n.\n.\n. ▶\n5 \n \nRetention/revocation of prior tax information authorizations. If the line 4 box is checked, skip this line. If the line 4 box \nisn’t checked, the IRS will automatically revoke all prior tax information authorizations on file unless you check the line 5 \nbox and attach a copy of the tax information authorization(s) that you want to retain \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\nTo revoke a prior tax information authorization(s) without submitting a new authorization, see the line 5 instructions.\n6 \n \nTaxpayer signature. If signed by a corporate officer, partner, guardian, partnership representative (or designated \nindividual, if applicable), executor, receiver, administrator, trustee, or individual other than the taxpayer, I certify that I have \nthe legal authority to execute this form with respect to the tax matters and tax periods shown on line 3 above.\n▶ IF NOT COMPLETED, SIGNED, AND DATED, THIS TAX INFORMATION AUTHORIZATION WILL BE RETURNED. \n▶ DON’T SIGN THIS FORM IF IT IS BLANK OR INCOMPLETE. \nSignature \nDate \nPrint Name \nTitle (if applicable) \nFor Privacy Act and Paperwork Reduction Act Notice, see the instructions. \nCat. No. 11596P \nForm 8821 (Rev. 01-2021) \n" ]
p5477sp.pdf	0121 Publ 5477 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5477sp.pdf	[ " \n \n \n \n \n \n \n \n \n \n \n \n \nTodos los contribuyentes \nahora son elegibles para un \nPIN de Protección \nde Identidad \nPara más detalles visite: IRS.gov/IPPIN \nEl PIN de Protección de Identidad (IP PIN) es un código de seis dígitos asignado \na contribuyentes elegibles y conocido sólo por el contribuyente y el IRS. Ayuda \na evitar que los ladrones de identidad presenten declaraciones de impuestos \nfraudulentas mediante el uso del número de Seguro Social de un contribuyente. \nAcerca del programa de suscripción \nde IP PIN: \n❯ Este es un programa voluntario. \n❯ Los contribuyentes deben pasar un riguroso \nproceso de verificación de identidad. \n❯ Los cónyuges y dependientes son elegibles \npara un IP PIN si pueden verificar sus \nidentidades. \n❯ Un IP PIN es válido para un año calendario. \n❯ Los contribuyentes deben obtener un IP PIN \nnuevo cada temporada de impuestos. \n❯ El IP PIN debe ingresarse correctamente en \nlas declaraciones de impuestos electrónicas \ny en papel para evitar rechazos y retrasos. \nCómo obtener un IP PIN: \nLos contribuyentes que desean un IP \nPIN deben ir a IRS.gov/IPPIN y usar la \nherramienta Obtenga un IP PIN. \nCuidado con las estafas para robar el IP PIN \nLos contribuyentes nunca deben compartir \nsu IP PIN con nadie más que con su \nproveedor de impuestos de confianza. El \nIRS nunca llamará, enviará un mensaje de \ntexto o correo electrónico para solicitar su \nIP PIN. \n***** \nPublication 5477 (sp) (1-2021) Catalog Number 75254W Department of the Treasury Internal Revenue Service www.irs.gov \n" ]
p5198sp.pdf	1220 Publ 5198 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5198sp.pdf	[ "Publication 5198 (sp) (Rev. 12-2020) Catalog Number 75171G Department of the Treasury Internal Revenue Service www.irs.gov\n¿Asiste usted o un miembro de su familia a \nla universidad o toma cursos para adquirir \no mejorar sus habilidades laborales?\nLos créditos tributarios podrían ayudar con el costo.\n¿Qué son los créditos tributarios por estudios?\nDos importantes créditos tributarios pueden ayudar a los estudiantes y a sus familias con el costo de la \nuniversidad u otros cursos de educación postsecundaria.\n1.\t\nEl Crédito tributario de oportunidad para los estadounidenses, en inglés (AOTC, por sus siglas en inglés),\npuede ayudar con el costo de los primeros cuatro años de universidad u otro programa de título o\ncertificado de postsecundaria si el estudiante asiste por lo menos medio tiempo. El crédito proporciona\nhasta $2,500 al año por estudiante durante hasta cuatro años, y hasta $1,000 por año pueden ser\nreembolsados incluso si la persona que reclama el crédito no está obligada a presentar una declaración\nde impuestos.\n2.\t\nEl Crédito perpetuo (vitalicio) por aprendizaje, en inglés (LLC, por sus siglas en inglés), puede ayudar con\nel costo de cualquier nivel de educación postsecundaria o cursos para adquirir o mejorar las habilidades\nlaborales. El crédito proporciona hasta $2,000 al año por declaración de impuestos.\n¿Cómo los estudiantes o sus familias reclaman el crédito?\nReclame el crédito en una declaración de impuestos federales para el año en que los gastos fueron pagados \npara usted, su cónyuge o su dependiente. Las universidades generalmente emiten a los estudiantes el \nFormulario 1098-T, Tuition Statement (Declaración de matrícula), en inglés, que contiene la información \nnecesaria para reclamar el crédito. Puede utilizar la herramienta del Asistente Tributario Interactivo en IRS.\ngov/es para saber si puede reclamar el crédito. \nPor cada estudiante, solo uno de los créditos se puede reclamar cada año tributario. \nLos estudiantes y sus familias deben considerar otros importantes beneficios tributarios, tales como el \ncrédito por otros dependientes (ODC, por sus siglas en inglés) y el crédito tributario por ingreso del trabajo \n(EITC, por sus siglas en inglés).\n¿Dónde los estudiantes y sus familias pueden obtener más información sobre los valiosos beneficios \ntributarios para la educación superior?\nVisite Créditos tributarios por estudios, en inglés, en irs.gov para encontrar todo lo que necesita saber.\n" ]
p5444.pdf	1220 Publ 5444 (PDF)	https://www.irs.gov/pub/irs-pdf/p5444.pdf	[ "Did You Receive \nUnemployment Benefits?\nHave the right tax withheld for 2020\n•\t Do I have to report unemployment benefits on\nmy federal income tax return?\nYes, any unemployment compensation received\nduring the year must be reported on your federal\ntax return.\n•\t How will I know how much unemployment\ncompensation I received?\nIf you received unemployment compensation\nduring the year, you should receive Form 1099-G\nfrom your state’s unemployment office.\n•\t How will unemployment compensation affect\nmy tax return?\nIf you do not have taxes withheld from your\nunemployment compensation, it could result in a\ntax liability.\n•\t Can I have federal income tax withheld from\nmy unemployment compensation?\nYes, you can choose to have federal income tax\nwithheld from your unemployment benefits by\ncontacting your state unemployment office.\n•\t If I am no longer collecting unemployment\nbenefits, how can I pay the tax due?\nYou can make estimated tax payments using\nForm 1040-ES and/or increase your withholding\nby completing Form W-4 once you have a new\njob. You can check your estimated withholding\nusing the calculator at www.irs.gov/W4app.\nSee www.irs.gov/payments for more payment\noptions.\nPublication 5444 (Rev. 12-2020) Catalog Number 74859V Department of the Treasury Internal Revenue Service www.irs.gov\nAccording to The Bureau of Labor Statistics, \nover 23 million U.S. workers have filed for \nunemployment this year nationwide.\nFor the first time, some self-employed \nworkers qualified for unemployment benefits.\nFor more information, contact your \nstate’s unemployment office and visit:\nwww.irs.gov/UC\nUnemployment benefits are taxable\nUnemployment benefits must be reported on your federal tax return. A record number \nof Americans are applying for unemployment compensation due to the COVID-19 \nOutbreak. If you received unemployment benefits, as well as the additional $600 per \nweek in coronavirus relief any time during the year, your tax return may be affected.\n" ]
p4190.pdf	0720 Publ 4190 (PDF)	https://www.irs.gov/pub/irs-pdf/p4190.pdf	[ "WHAT DIFFERENCES ARE THERE IN REPORTING MY RETIREMENT INCOME \nAND MY INCOME (EARNED) DURING MY WORK CAREER?\nWhen you received your Form W-2, Wage and Tax Statement prior to retirement, you reported your wages on an \nindividual income tax return, such as Form 1040, U.S. Individual Income Tax Return. You also may have received self-\nemployment income on Form 1099-NEC, Nonemployee Compensation, if you were a contractor/subcontractor or if \nyou performed independent projects or services. You reported your income by attaching a Schedule C, Profit or Loss \nFrom Business (Sole Proprietor) and Schedule SE, Self-employment Tax to your Form 1040. After you formally retire, \nyou would do the same if you continue to receive these types of income.\nWhen retired, you may receive a Form SSA-1099 for social security benefits and/or a Form 1099-R for pension \nincome. You will include these types of retirement income on your Form 1040, in addition to any other income you \nmay have received during the tax year.\nWHAT TYPES OF INCOME ARE TAXABLE?\nThe types of income which are taxable include, but are not limited to: military retirement pay, all or part of pensions \nand annuities, all or part of Individual Retirement Accounts (IRA), unemployment compensation, gambling income, \nbonuses and awards for outstanding work, alimony or prizes. A portion of your social security benefits may be taxable \nbased on your other income and filing status.\nFor additional information see Publication 525, Taxable and Non-taxable Income\nWHAT TYPES OF INCOME ARE NON-TAXABLE?\nSome income is not subject to tax. A few examples are veteran’s benefits, disability pay for certain military or \ngovernment related incidents, worker’s compensation, and cash rebates from a dealer or manufacturer of an item you \npurchase.\nFor additional information see Publication 525, Taxable and Non-taxable Income\nWHY IS MY PENSION INCOME TAXED?\nYour pension will be reported on a Form 1099-R, Distributions From Pensions, Annuities, Retirement or Profit-Sharing \nPlans, IRAs, Insurance Contracts, etc. Form 1099-R will show you how much you contributed to the plan and how \nmuch tax was withheld. Your pension could be fully or partially taxable depending on how the money was put into the \npension plan. If all the money was contributed by the employer or the money was not taxed before going into the plan \n(pre-tax), it would be taxable. When your contributions (basis) to the plan are from already-taxed dollars (after-tax), \nthat part is not taxed, but must be recovered over your life expectancy. For new retirees, you will generally use the \n\"simplified method\" to compute the taxable portion of your pension. The worksheet to determine the taxable and non-\ntaxable portion of your pension and annuity income is in the Instructions for Form 1040 and Form 1040-SR. \nFor additional information see Publication 575, Pension and Annuity Income.\nCONTINUED...\nLIFECYCLESERIES\nTax Guide \nfor the Retiree\nThis brochure is intended for individuals who recently retired or \nhave retirement plans in their near future\nFREQUENTLY ASKED QUESTIONS\n", "CAN MY PENSION BE TAKEN OUT AS ONE LUMP-SUM PAYMENT?\nIf you withdraw the full amount in your pension account, part or all will be taxable in the year received. You may \nwant to consider rolling it over into another pension plan or a traditional IRA to avoid paying a large amount of tax \nin one year.\nNOTE: Before withdrawing any funds from a retirement account (IRA, 401-K, Thrift Savings, etc.), consult with a tax professional to \nunderstand potential tax consequences.\nWHEN AM I REQUIRED TO WITHDRAW MONEY FROM MY RETIREMENT \nACCOUNTS?\nYour required minimum distribution (RMD) is the minimum amount you must withdraw from your account each \nyear. You generally have to start taking withdrawals from your IRA, SEP IRA, SIMPLE IRA, or retirement plan \naccount when you reach age 72 (70 ½ if you reach 70 ½ before January 1, 2020). However, the first payment \ncan be delayed until April 1 of 2020 if you turn 70½ in 2019. If you reach 70½ in 2020, you have to take your first \nRMD by April 1 of the year after you reach the age of 72. For all subsequent years, including the year in which \nyou were paid the first RMD by April 1, you must take the RMD by December 31 of the year.\nRoth IRAs do not require withdrawals until after the death of the owner.\nFor additional information see Publication 575, Pension & Annuity Income and Publication 590-B, \nDistributions for Individual Retirement Arrangements (IRAs).\nNOTE: The RMD rule is waived for tax year 2020 under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.\n\u0007\nHOW DO I DETERMINE HOW MUCH OF MY SOCIAL SECURITY IS TAXABLE?\nCompare the base amount found in Publication 915, Social Security and Equivalent Railroad Retirement \nBenefits, to the total of one-half of your social security benefits plus all of your other income (including tax-\nexempt income). If the base amount exceeds your income computation, then your social security is non-taxable. \nFor the most complete calculation, you should use the worksheets found in Publication 915 or the instruction \nbooks for the 1040 series.\nI AM RETIRED AND RECEIVE SOCIAL SECURITY, BUT I HAVE NOW TAKEN \nA PART TIME JOB. WHY ARE THEY TAKING SOCIAL SECURITY TAXES OUT \nOF MY PAY?\n\u0007\nThe Federal Insurance Contribution Act, or FICA, provides for a Federal System of old-age, survivors, disability, \nand hospital insurance. The old-age, survivors, and disability insurance part is financed by the social security \ntax. Generally, employee wages are subject to social security and Medicare taxes regardless of the employee’s \nage or whether he or she is receiving social security benefits.\nWILL TAXES BE WITHHELD FROM MY INCOME OR WILL I HAVE TO MAKE \nESTIMATED TAX PAMENTS? \nOur tax law provides for a pay-as-you-go system which requires taxes to be paid on income as it is received. \nThere are two ways which taxes are typically paid: \n\u0007\nTax Withholding – You can request federal tax be withheld from your pension, social security, unemployment \ncompensation, etc., by submitting the appropriate following form to the payer of the income:\n\t\ny Form W-4, Employee's Withholding Certificate - Used for wages and military retirement pay \n\t\ny Form W-4P, Withholding Certificate for Pension or Annuity Payments - Used for pensions and annuities\n\t\ny Form W-4V, Voluntary Withholding Request - Used for social security, unemployment compensation, and \nrailroad retirement income\nTo ensure you do not have too much or too little income tax withheld use the Tax Withholding Estimator. You \nmay use the results of this program to complete the appropriate withholding form.\nCONTINUED...\nLIFECYCLESERIES\n", "\u0007\nEstimated Tax Payment – If you have not paid enough federal tax through withholding or receive income that \nis not subject to withholding, you should make estimated tax payments . Use the worksheet in Form 1040-ES, \nEstimated Taxes for Individuals to figure the amount of estimated taxes to pay to Internal Revenue Service (IRS). \n \nYou can mail a check or money order with Form 1040-ES voucher or make a payment through one of the online \npayment options. Paying online is convenient and secure and helps make sure we get your payments on time. \nTo pay your taxes online or for more information, go to IRS.gov/Payments. \nEstimated tax payments are due each year on April 15th, June 15th, September 15th, and January 15th of the \nfollowing year.\nExample: John realizes that selling his mutual funds in December resulted in a large gain. He can estimate the\neffect of that gain and pay the amount by January 15th, to avoid a penalty.\n\u0007\nNOTE: If you do not make sufficient and timely federal tax payments, you could incur an estimated tax penalty.\nFor additional information see Publication 505, Tax Withholding and Estimated Tax.\nWHERE CAN I CHANGE MY WITHHOLDING IF I'M A MILITARY RETIREE?\nThere are two ways to change your withholding. You can call the Retiree Pay customer service number at \nDefense Finance and Accounting Service (DFAS) at 1-800-321-1080 or you can make changes online via \nDFAS’s myPay secure web-based pay management system. The myPay system lets active duty military, \nNational Guard and Reserve members, some federal government civilian employees, and military retirees \nand annuitants quickly change pay information like federal and state withholding. If you are a myPay account \nholder, log in at https://mypay.dfas.mil. If you want to set up a new account or need help with your existing \naccount, call the myPay customer service center at 1- 877-363-3677.\nADDITIONAL INFORMATION \nFor a free paper copy of any listed form or publication, place an order online or call 1-800-829-3676 (1- \n800-TAX-FORM).\nFor additional questions about your tax responsibilities, utilize the Interactive Tax Assistant (ITA). The ITA tool \nis a tax law resource that takes you through a series of questions and provides you with responses to tax law \nquestions. If a specific topic isn't covered by the tool, then try the Tax Topics application or call 1-800-829-1040.\nPUBLICATIONS THAT MAY BE OF ASSISTANCE:\n\t\ny Publication 501, Dependents, Standard Deduction, and Filing Information\n\t\ny Publication 554, Tax Guide for Seniors\n\t\ny Publication 560, Retirement Plans for Small Business\n\t\ny Publication 721, Tax Guide to U.S. Civil Service Retirement Benefits\n\t\ny Publication 939, General Rule for Pensions and Annuities\nFREE TAX RETURN ASSISTANCE\nVolunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) Sites offer free tax return \npreparation to individuals having low to moderate income. To find free tax help near you, call IRS at 800-906-\n9887 or AARP TaxAide at 1-888-227-7669.\nLIFECYCLESERIES\nPublication 4190 (Rev. 7-2020) Catalog Number 36562Z Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
f14781.pdf	1220 Form 14781 (PDF)	https://www.irs.gov/pub/irs-pdf/f14781.pdf	[ "Catalog Number 69159Q\nwww.irs.gov\nForm 14781 (Rev. 12-2020)\nForm 14781 \n(December 2020)\nDepartment of the Treasury - Internal Revenue Service\nElectronic Federal Tax Payment System (EFTPS) – \nInsolvency Registration\nOMB Number \n1545-1467\nFor questions or more information please call EFTPS Provider Help Desk at 1-866-553-9413. \nWhen your form is completed, please send by facsimile to: Internal Revenue Service, Attn: Ricardo Perez, Fax number 855-536-3484.\nTrustee Information\n1. Trustee Taxpayer Identification Number (TIN) (enter your Trustee nine-digit Employer Identification Number, without dashes)\n2. Trustee name (print/type) (the only valid characters are A-Z, 0-9, -, &, and blank)\n3. Trustee address (print/type your mailing address)\nCity\nState\nZIP code\n–\nContact Information\n4. Primary contact name (print/type the name of a person who can be contacted in the event \nquestions arise regarding this form)\nPrimary contact telephone number\nArea code\n/\n–\nPrimary contact email address\n.\nSoftware Vendor & Bank Information\nSoftware Vendor and Bank Name (print/type name vendor and phone number of your software, and name of your bank)\n5. Software vendor name\nSoftware vendor telephone number\nArea code\n/\n–\nBank name\nTrustee Signature\nThe registration from must be signed to authorize participation in the EFTPS program.\n6. If signed by a Corporate Officer, Partner, or Fiduciary on behalf of the trustee, he/she certifies that the undersigned has the authority \nto execute this authorization on behalf of the trustee\nAuthorized signature\nDate\nName (print/type)\nTitle\nThis form can be mailed or sent via facsimile (see information at the top of this form.)\nSIGN\n" ]
p5081sp.pdf	1220 Publ 5081 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5081sp.pdf	[ "Productos en línea de utilidad\nHerramienta \ninteractiva\nFormularios y publicaciones\nMás recursos\n¿Reúno los \nrequisitos \npara reclamar \nuncrédito por \nestudios? (en \ninglés)\nAverigüe si \npuede reclamar \nestos beneficios \neducativos para \nusted, su cónyuge o \nsu dependiente.\nPublicación 970 (PDF, en inglés), Tax Benefits for Education\n(Beneficios tributarios por estudios)\nPublicación 4772 (SP) (PDF), Folleto sobre el crédito tributario de \noportunidad para los estadounidenses\nFormulario 8863 (PDF, en inglés), Education Credits (Créditos \ntributarios por estudios) y las Instrucciones para el Formulario8863 \n(PDF, en inglés)\nFormulario 1098-T (PDF, en inglés),Tuition Statement (Declaración \ndematrícula)\nFormulario 1098-E (PDF, en inglés), Student Loan Interest Statement \n(Declaración de intereses sobre préstamos para estudios)\nPublicación 929 (PDF, en inglés),Tax Rules for \nChildren and Dependentes (Reglas tributarias para \nhijos y dependientes)\nPublicación 519 (PDF, en inglés), U.S. Tax Guide \nfor Aliens (Guía tributaria de los Estados Unidos \npara extranjeros), ayudará a determinar el estatus de \nun individuo, así como proporciona la información \nnecesaria para presentar una declaración de \nimpuestos.\nLo que necesita saber sobre los créditos \ntributarios por estudios, en inglés\nSitio web del Departamento de Educación en: \nwww.ed.gov\nObtenga más información sobre el AOTC y el LLC\nNo importa qué crédito tome, el AOTC y el LLC son créditos valiosos que pueden ayudar con el alto costo \nde la educación. Pulse en los enlaces a continuación para utilizar cualquiera de nuestros productos de las \nredes sociales o visite Lo que necesita saber sobre los créditos tributarios por estudios, en inglés, \nen www.irs.gov, para obtener más información sobre el AOTC, el LLC y otros beneficios para la educación \nConsulte la tabla comparativa, en \ninglés, del AOTC y el LLC. \n\nEsta comparación en paralelo puede \nayudarle a determinar cuál crédito \nfunciona mejor para usted y su familia.\n¿Aún no está seguro de cuál \ncrédito es más beneficioso \npara usted reclamar?\nCréditos tributarios por estudios\nGuía de recursos en línea\n¿Qué es el AOTC?\nEl Crédito tributario de oportunidad para los estadounidenses (AOTC, por sus siglas \nen inglés), está disponible para los gastos calificados pagados, incluso la matrícula y los \nmateriales del curso requeridos, durante los primeros cuatro años de educación postsecundaria \nde un estudiante. Se reclama por los gastos pagados durante el año para usted, su cónyuge \no su dependiente. Es de hasta $2,500 por estudiante, y hasta $1,000 del crédito pueden ser\nreembolsados incluso si la persona que reclama el crédito no está obligada a presentar o no\nadeuda ningún impuesto. El estudiante debe asistir como mínimo a medio tiempo y el crédito\nse puede reclamar por el estudiante durante un máximo de cuatro años.\n¿Qué es el LLC?\nEl Crédito perpetuo (vitalicio) por aprendizaje (LLC, por sus siglas en inglés), está disponible \npara los gastos calificados pagados por todos los años de educación postsecundaria o cursos \npara adquirir o mejorar las habilidades de trabajo. Se reclama por los gastos pagados \ndurante el año para usted, su cónyuge o su dependiente. Es de hasta $2,000 por declaración \nde impuestos. Con el LLC no hay requisito mínimo de inscripción o límite en el número de años \nque el crédito puede reclamarse.\nPor cada estudiante, solo uno de los créditos se puede reclamar cada año tributario.\nDeducción de las matrículas y cuotas \nEs posible que pueda deducir los gastos de estudios calificados pagados durante el año para \nusted, su cónyuge o su dependiente. La deducción de las matrículas y cuotas puede reducir la \ncantidad de sus ingresos tributables hasta $4,000. Reclame esta deducción en el Formulario \n8917 (PDF, en inglés), Tuition and Fees Deduction (Deducción de las matrículas y cuotas). No \npuede reclamar la deducción de los gastos de un estudiante en algún año en que reclame el \nAOTC o el LLC por el estudiante.\nTwitter\nYouTube\nInstragram\nPublication 5081 (sp) (12-2020) Catalog Number 75198X Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
p5426.pdf	0121 Publ 5426 (PDF)	https://www.irs.gov/pub/irs-pdf/p5426.pdf	[ "Internal Revenue Service \| Taxpayer First Act\n1\nTAXPAYER FIRST ACT\nREPORT TO CONGRESS\nJanuary 2021 \nPublication 5426 (1-2021) Catalog Number 74637F Department of the Treasury Internal Revenue Service www.irs.gov\n", "2\nSECTION \n \n \n \n \n2 \n3\n4\n5\n1\n.0 COMMISSIONER’S WELCOME\n11\n2.0 EXECUTIVE SUMMARY\n14\n3.0 OUR APPROACH\n28\n4.0 TAXPAYER EXPERIENCE STRATEGY\n33\n4.1 INTRODUCTION AND EXPLANATION OF STRATEGY\n34\n4.2 MEASURING SUCCESS\n38\n4.3 EXPANDED DIGITAL SERVICES\n41\n4.4 SEAMLESS EXPERIENCE\n46\n4.5 PROACTIVE OUTREACH AND EDUCATION\n53\n4.6 COMMUNITY OF PARTNERS\n58\n4.7 \nFOCUSED STRATEGIES FOR REACHING \nUNDERSERVED COMMUNITIES\n63\n4.8 ENTERPRISE DATA MANAGEMENT AND\n ADVANCED ANALYTICS\n69\n5.0 TRAINING STRATEGY\n73\n5.1 INTRODUCTION AND EXPLANATION OF STRATEGY\n74\n5.2 IRS UNIVERSITY\n77\n5.3 TAXPAYER-FIRST TRAINING\n80\n5.4 CONTINUOUS LEARNING FOR ALL EMPLOYEES\n81\n5.5 UTILIZING TECHNOLOGY\n85\n5.6 MEASURING SUCCESS\n86\nTABLE OF CONTENTS\nSECTION \nSECTION \nSECTION \nSECTION \n1 \n7\nPROLOGUE\n", "6\n7\n6.0 ORGANIZATIONAL REDESIGN STRATEGY\n93\n6.1 INTRODUCTION AND EXPLANATION OF STRATEGY\n94\n6.2 PROPOSED FUTURE ORGANIZATIONAL\nSTRUCTURE AND DIVISIONS\n96\n6.3 COMMISSIONER DIRECT REPORTS\n97\n6.4 RELATIONSHIPS AND SERVICES DIVISION\n105\n6.5 COMPLIANCE DIVISION\n110\n6.6 ENTERPRISE CHANGE AND INNOVATION DIVISION 113\n6.7 OPERATIONS MANAGEMENT DIVISION\n116\n6.8 INFORMATION TECHNOLOGY DIVISION\n118\n6.9 MEASURING SUCCESS AND ADDITIONAL \nCONSIDERATIONS\n120\n6.9.1 MEASURING SUCCESS\n120\n6.9.2 NON-STRUCTURAL COMPONENTS CRITICAL \nTO SUCCESS\n124\n7\n.0 KEY CONSIDERATIONS\n128\n7\n.1 INTERNAL REVENUE MANUAL GUIDANCE\n130\n7\n.2 CHANGE MANAGEMENT\n131\n7\n.3 COMMUNICATIONS PLAN\n133\n7\n.4 RESOURCE CONSIDERATIONS\n134\n8.0 \n IRS NEXT STEPS\n137\n8\nSECTION \nSECTION \nSECTION \nTABLE OF CONTENTS\n3\n", "9\n9.0 APPENDIX\n140\n9.1 METHODOLOGY OVERVIEW\n141\n9.1\n.1 ESTABLISHING THE TAXPAYER FIRST ACT OFFICE 141\n9.1\n.2 RESEARCH AND INFORMATION GATHERING\n141\n9.2 STRATEGIC ALIGNMENT\n144\n9.3 STATUS OF THE 42 OPERATING DIVISION \n PROVISIONS\n145\n9.3.1 EXECUTING DIVISION PROVISIONS\n147\n9.4 COMMUNICATIONS AND OUTREACH\n151\n9.4.1 INTERNAL COMMUNICATIONS VEHICLES\n151\n9.4.\u0013\n INTERNAL OUTREACH ACTIVITIES \n 160\n9.4.3 INTERNAL COMMUNICATIONS AND OUTREACH \n ACTIVITIES ANALYSIS\n163\n9.4.4 EXTERNAL COMMUNICATION VEHICLES\n164\n9.4.5 EXTERNAL OUTREACH ACTIVITIES\n166\n9.4.6 EXTERNAL COMMUNICATIONS AND OUTREACH \n ACTIVITIES ANALYSIS\n174\n9.5 COSTING METHODOLOGIES AND DETAILED COSTS\n175\n9.5.1 COSTING METHODOLOGIES \n175\n9.5.2 ESTIMATED COSTS\n178\n9.6 TAXPAYER EXPERIENCE ADDITIONAL INFORMATION\n181\n9.6.1 STRATEGIC GOAL: UNDERSTAND, INFORM AND \nEDUCATE TAXPAYERS\n182\n9.6.2 STRATEGIC GOAL: PROVIDE A SEAMLESS \n TAXPAYER EXPERIENCE \n187\n9.6.3 STRATEGIC GOAL: EMPOWER, EQUIP AND ENABLE \nWORKFORCE \n192\n9.6.4 ENABLERS \n196\nSECTION \nTABLE OF CONTENTS\n4\n", "TABLE OF CONTENTS\n9.6.5 INTERNAL REVENUE MANUAL ADDITIONAL \nINFORMATION \n197\n9.7 ORGANIZATIONAL REDESIGN ADDITIONAL \nINFORMATION \n198\n9.7\n.1 COMMISSIONER DIRECT REPORTS ALIGNMENT TO \nOVERSIGHT RECOMMENDATIONS\n200\n9.7\n.2 RELATIONSHIPS AND SERVICES DIVISION \n ALIGNMENT TO OVERSIGHT RECOMMENDATIONS 202\n9.7\n.3 COMPLIANCE DIVISION ALIGNMENT TO \nOVERSIGHT RECOMMENDATIONS\n203\n9.7\n.4 ENTERPRISE CHANGE AND INNOVATION DIVISION \nALIGNMENT TO OVERSIGHT RECOMMENDATIONS 204\n9.7\n.5 OPERATIONS MANAGEMENT DIVISION ALIGNMENT \nTO OVERSIGHT RECOMMENDATIONS\n205\n9.7\n.6 INFORMATION TECHNOLOGY DIVISION ALIGNMENT \nTO OVERSIGHT RECOMMENDATIONS\n205\n9.7\n.7 \n CRIMINAL INVESTIGATION\n206\n9.7\n.8 CYBERSECURITY\n210\n9.7\n.9 POLICY AND LEGISLATION \n214\n9.7\n.10 EXTERNAL OVERSIGHT AND ADVISORY \n215\n9.7\n.11 GOVERNANCE \n216\n9.7\n.12 CURRENT TO FUTURE ORGANIZATIONAL \n STRUCTURE CROSSWALK \n 220\n9.8 FUNDING ALIGNMENT\n221\n9.8.1 NEW APPROPRIATIONS STRUCTURE\n221\n9.8.2 ORGANIZATIONAL ALLOCATION OF FUNDING \n223\n9\nSECTION \n5\n", "TABLE OF CONTENTS\n10\nSECTION \n6\n10.0 \nBIBLIOGRAPHY\n224\n10.1 \nOVERSIGHT REPORTS, TESTIMONIES AND \nRECOMMENDATIONS\n224\n10.2 \nCUSTOMER SATISFACTION SURVEY RESULTS\n232\n10.3 PUBLICATIONS, STUDIES, BRIEFINGS \nAND STATU5ES \n237\n", "PROLOGUE\n7\nInternal Revenue Service \| Taxpayer First Act \n7\nInternal Revenue Service \| Taxpayer First Act\nPROLOGUE \nThe Taxpayer First Act (TFA) was enacted on July 1st, 2019 with strong bipartisan support to re-\nimagine and enhance the way we serve taxpayers, continue to enforce the tax laws in a fair and \nimpartial manner, and train IRS employees to deliver a world-class customer experience. The \nAct consists of 45 provisions, including specifc mandates to improve the taxpayer experience. \nThere are three provisions requiring the development of the critical plans included in this report \n(Taxpayer Experience, Training, and Organizational Redesign). These plans lay out a vision to \nrevolutionize tax administration in our country for the 253 million citizens who interact with the \nIRS annually, and ensure that the $3.6 trillion of federal revenue that the IRS collects annually \nwill continue. This is an aspirational vision that builds on work that is already underway and \nprovides an investment framework for evaluating IRS funding levels in future years. However, \nwithout the commitment of signifcant multi-year funding, the IRS cannot make the taxpayer \nimprovements necessary to maintain trust and confdence in the federal government and its tax \ncollection system.\nHigh-quality, personalized service is key to helping taxpayers understand and comply with their \nfling and reporting obligations, well-trained employees provide excellent taxpayer service, and \na streamlined organizational structure makes it easier for taxpayers and employees to navigate \nthe agency and get the help they need when they need it. Strong technology infrastructure is \ncritical to delivering on this vision. The Integrated Modernization Business Plan, delivered in \nApril 2019, was developed to establish the underlying infrastructure required to modernize the \nIRS. However, the initial funding requested for modernization only takes us so far. While the \nIntegrated Modernization Business Plan lays the foundation for improving the taxpayer and \nemployee experience, the Taxpayer First Act requires us to build upon this foundation to deliver \nthe experience taxpayers expect. \nThe IRS currently estimates that full implementation of the Taxpayer First Act plans and \nIntegrated Modernization Business Plan would cost $4.1 billion over the fve-year period from \nFY2021 – FY2025 broken into three broad categories: \n• \nTFA Legislatively Mandated Provisions: $550 million over fve years to implement specifc \nmandates outlined in the act, apart from the development and implementation of strategies\n• \nTFA Strategy Development and Implementation: $1.6 billion over fve years to develop \nand implement the Taxpayer Experience, Training and Organizational Redesign plans \nrequired by the TFA\n• \nIRS Modernization Plan: $1\n.9 billion associated with achieving necessary modernization of \nIRS systems, cybersecurity and operations\nAdditional costing details can be found in the Appendix 9.5.2.\n", "PROLOGUE\n8\nInternal Revenue Service \| Taxpayer First Act \n8\nInternal Revenue Service \| Taxpayer First Act\nIn addition, in FY2020 the IRS spent $68 million on the implementation of TFA legislatively \nmandated provisions. FY2020 expenses were funded out of our original budget allocation as \nno funding was specifcally appropriated to cover those needs. Our FY2021 budget submission \nrequested funding of $106 million for implementation of the legislatively mandated provisions of \nthe Taxpayer First Act and $300 million for the Modernization Plan. \nThe TFA mandates included in the Act are aimed at strengthening taxpayer rights, modernizing \nthe IRS and combating identity theft and fraud. The IRS estimates that full implementation of \nthese requirements by FY2025 would cost an additional $444 million, roughly $111 million per \nyear, above the amounts previously committed or requested. Some of the provisions that require \nsignifcant additional investments include: \n• \nProvision 1001, Establishment of IRS Independent Office of Appeals: Renames the IRS \nOffice of Appeals as the IRS Independent Office of Appeals and adds new rules that require \nthe Independent Office of Appeals to make its referred case fles available to:\n• \nIndividuals with adjusted gross incomes of $400,000 or less for the tax year to which \nthe dispute relates;\n• \nEntities with gross receipts of $5 million or less for the tax year to which the dispute \nrelates.\nIn addition, when the IRS or Chief Counsel has issued a notice of defciency to a taxpayer \nand denies the taxpayer’s request for referral to the IRS Independent Office of Appeals, the \nIRS must now issue a notice to explain the reasons. It also needs to tell the taxpayer how to \nprotest the denial. \n• \nProvision 2102, Internet Platform for 1099 Filings: Requires the IRS to develop an \nInternet portal by Jan. 1, 2023 that allows taxpayers to electronically fle Forms 1099. The \nwebsite will provide taxpayers with IRS resources and guidance, and allow them to prepare, \nfle and distribute Forms 1099, and create and maintain tax records. \n• \nProvision 2005, Identity Protection Personal Identifcation Numbers: Requires the \nSecretary to establish a program to issue an Identity Protection (IP) PIN to any U.S. resident \nwho requests one. Additionally, the Act requires the Secretary to expand the issuance of IP \nPINs every year and ensure nationwide availability within fve years. \n• \nProvision 3101, Mandatory E-fling by Exempt Organizations: Extends the requirement \nto e-fle to all tax-exempt organizations required to fle statements or returns in the Form 990 \nseries or Form 8872 (Political Organization Report of Contributions and Expenditures). The \nAct also requires that the IRS make the information provided on the forms available to the \npublic in a machine-readable format as soon as possible. \n", "PROLOGUE\n9\nInternal Revenue Service \| Taxpayer First Act \n9\nInternal Revenue Service \| Taxpayer First Act\nThe IRS stands ready to begin a new era in tax administration that is: \n•\nTaxpayer Focused: We should provide interactions that are efficient, informative,\npersonalized and convenient. Taxpayers should have the information they need to understand\nand comply with their taxes. Key elements of this program include:\n•\nExpanded Digital Services: Simplifying the tax process with enhanced mobile\nand online experiences, digital fling and payment options, and online portals for tax\nprofessionals.\n•\nSeamless Experience: Enhancing self-service capabilities and IRS-assisted service\ncapabilities, expanding access to the IRS by providing taxpayers with their preferred\nchannel of service (website, telephone, in person, etc.) and integrating those\nchannels to provide a seamless experience throughout the taxpayer lifecycle.\n•\nProactive Outreach and Education: Providing clear and timely communications,\nimproving how and when we provide information to taxpayers by using new\ntechnology, applying behavioral insights, expanding our social media strategy, and\nmaking use of our trusted partnerships.\n•\nCommunity of Partners: Building on our existing partnerships and developing\nnew partnerships to create an interactive network of trusted partners across the tax\ncommunity.\n•\nFocused Strategies for Reaching Underserved Communities: Establishing\nspecifc strategies to engage with underserved communities to address issues of\ncommunication, education, transparency, trust, and access to quality products and\nservices, including providing customized education and outreach in the languages\nspoken by specifc taxpayer groups.\n•\nEnterprise Data Management and Advanced Analytics: Developing a secure data\nmanagement strategy that includes an agency-wide understanding of operational\ndata and applying advanced analytics to better understand taxpayer needs to improve\nservice and compliance.\n", "PROLOGUE\n1\n0\nInternal Revenue Service \| Taxpayer First Act \n10\nInternal Revenue Service \| Taxpayer First Act\n• \nEmployee Focused: Our employees should be well-trained, adaptable, highly motivated and \ncustomer-focused. IRS employees would receive comprehensive and thorough training - both \nsubstantively (on the law and mechanics) and attitudinally (utilizing world-class customer \nexperience techniques). Key elements of this program include:\n• \nStreamlining current training processes through the creation of a centralized \neducational organization, or “IRS University” to support the IRS mission.\n• \nDeveloping annual training on taxpayer rights and focusing employee training on \nearly, fair, and efficient resolution of taxpayer disputes.\n• \nEnsuring consistent skill development and employee evaluations across the IRS.\n• \nDelivered Efficiently: We are modernizing our organizational structure to better align \noperations with our mission, increase agency-wide collaboration, and deconstruct \noperational silos. Key elements of this program include:\n• \nRealigning the IRS’s organizational structure to increase consistency across \ncompliance functions and taxpayer services. \n• \nImproving the leadership structure, reducing organizational redundancies and \nremoving silos. \n• \nProviding solutions to best position the IRS to combat cybersecurity and other \nthreats.\nCompliance with the statutory requirements of the TFA, including the full implementation of \nthe strategies included in this report and the key TFA mandates, will fundamentally change \nthe taxpayer experience. This would improve trust and confdence in the IRS which can result \nin improved compliance, reducing the tax gap and benefting every taxpayer. But we must \nfrst improve our core technology infrastructure. To truly “Put Taxpayers First” and successfully \nimplement the Taxpayer First Act, the IRS needs adequate funding. Investing in the IRS \nrepresents an investment in the future of the United States and the delivery of important \nservices every American deserves.\n", "1.0 \| COMMISSIONER’S WELCOME\n1\nInternal Revenue Service \| Taxpayer First Act \n1.0 \nCOMMISSIONER’S \nWELCOME\nI am pleased to provide you with this report on the progress we have made to implement \nthe Taxpayer First Act and our Taxpayer Experience, Training and Organizational Redesign \nStrategies. As the Commissioner of the Internal Revenue Service (IRS), I would like to thank the \nCongress for providing us with a great opportunity to reimagine the way the IRS does business. \nSigned into law on July 1, 2019, the TFA gives us the opportunity to shape our future and rethink \nthe way we operate. In particular, the way we interact with taxpayers, the way that we train our \nemployees, and the way we structure our organization are important foundations for our future \nsuccess. This report lays out a vision to fundamentally change the way we operate, building \nupon our strengths, with additional focus on areas to improve the important service we provide \nto our great country.\nMore than 20 years ago, the IRS Restructuring and Reform Act of 1998 led to signifcant \nchanges, including increased taxpayer rights and our organizational design based on taxpayer-\nsegment focused operating divisions. While those changes served tax administration well, \nthe world has evolved. The IRS must consider the increased role of technology in our lives, \nglobalization, and our diverse and expanding taxpayer base. If enabled by adequate funding, \nTFA gives us a chance to transform the IRS into a true 21st century Agency. \nIn this report, we explain our vision for the Taxpayer Experience, Training, and Organizational \nRedesign Strategies required by the TFA and our implementation progress to date. By integrating \nour three Strategies, we will train and empower IRS employees to deliver exceptional taxpayer \nservice within an efficient organizational structure. Throughout the report, you will fnd a \nconsistent theme of improved technology, seamless service, and access for all taxpayers. I hope \nyou will share my excitement about our path to transform the IRS into a trusted, user-friendly, \n11\n", "1.0 \| COMMISSIONER’S WELCOME\n1\n2\nInternal Revenue Service \| Taxpayer First Act \ndigital enterprise accessible to all taxpayers, regardless of location, occupation, educational \nlevel, or language profciency. \nWhile some of our plans are aspirational, I want to emphasize that we are committed to tangible, \nlasting reform. Taxpayers will see improvements over the next 1-2 years as we more deliberately \nintegrate and design services, and incrementally expand our capabilities. Our goal is for the IRS \nto evolve into an organization that anticipates their needs and proactively communicates easy-\nto-understand information in the languages they prefer. Similarly, tax professionals should have \naccess to the information they need and be empowered to collaborate with the IRS to further \ninnovate and improve the taxpayer experience. We will continue to build upon our current use \nof data analytics to drive efficient decision making and implement changes. We are committed \nto ensuring that our programs and services are accessible to all our customers, fairly, and \nequitably, with emphasis on reaching traditionally underserved communities. We can accomplish \nall of this and more in partnership with the Congress, taxpayers, tax practitioners and other \nstakeholders. \nIRS employees are key stakeholders in this effort. During my tenure at the IRS, I have been \nconstantly amazed at the talent and diligence of our employees, their desire to serve taxpayers \nand the pride they have as civil servants. Although we have faced a number of challenges in a \nshort time, from the 35-day government shut-down in 2019 to the ongoing COVID-19 pandemic, \nour employees continue to collect the funds to support our nation and deliver payments to assist \nAmericans. Through this spirit and the desire to do the right thing for taxpayers we serve, the \nIRS has developed what I believe are the strongest strategies to drive our agency into the future.\nOur TFA team worked diligently and collectively with the IRS leadership team over the past year \nto research, listen, learn and synthesize information from many sources. These sources include \nIRS employees, taxpayers, tax professionals, oversight partners and other external stakeholders. \nThe amount of feedback collected is nothing short of phenomenal, and I am proud of the report \n12\n", "1.0 \| COMMISSIONER’S WELCOME\n1\n3\nInternal Revenue Service \| Taxpayer First Act \nwe produced. That being said, the work is not yet done. It will take major effort, strategy and \nfunding to execute the plans we have made. The listening does not stop with the information we \nhave collected. We will implement continuous feedback loops to hear from taxpayers and our \nstakeholders. \nAs you will read, the full report includes both near term operational plans and a long term \naspirational vision. We recognize that it will take additional planning and funding to execute the \nplans outlined in these strategies. I trust that you will recognize the strength and vision in the \nstrategies we present and provide the support the IRS requires to execute them in the coming \nyears. I am also confdent our efforts to be more transparent and transform the IRS will increase \ntrust in the IRS, improve voluntary compliance and assist all taxpayers in meeting their tax \nobligations to provide crucial funding for our nation’s operations. \nThe future of the IRS belongs to us. If we stand together, focused on our mission, there is no \nlimit to what we can do. \nThank you,\nCharles P\n. Rettig\nIRS Commissioner \n13\n", "14\nInternal Revenue Service \| Taxpayer First Act\nS E C T I O N2\nInternal Revenue Service \| Taxpayer First Act \nSUMMARY\nEXECUTIVE\nInternal Revenue Service \| Taxpayer First Act \n", "15\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\n2.0 EXECUTIVE SUMMARY \nThe IRS operates at an unparalleled level of scale and complexity. We aim to provide America’s \ntaxpayers top-quality service by helping them understand, enable them to voluntarily comply, \nand meet their tax responsibilities while enforcing the law with integrity and fairness to all. In \nFY2019, the IRS collected more than $3.56 trillion in gross taxes and issued almost 122 million \nrefunds1 - all amounting to more than $452 billion in tax refunds. All of this is possible because \nof our workforce; the approximately 75,000 dedicated public servants that take pride in serving \ntaxpayers and their country. \nThis report describes how we can transform the IRS into a modern, efficient, and taxpayer-\ncentric centered agency. One that is easily accessible for all taxpayers, including traditionally \nunderserved communities. The report outlines three strategies that build upon one another: \nTaxpayer Experience, Training and Organizational Redesign. Our Taxpayer Experience, Training, \nand Organizational Redesign Strategies will re-shape the IRS into a nimbler enterprise, readily \ncapable of taking advantage of emerging technology. These strategies are built upon the \nexceptional work the IRS is already doing, but in many other ways, they are aspirational. We \nintend for the strategies described in this report to reimagine the taxpayer experience. Our \nstrategies will guide our future strategic planning efforts and we will continue to coordinate \nacross the agency to align on new initiatives. We will leverage the Taxpayer First Act strategies \nto inform our FY2022-2026 Strategic Plan. While the strategies are fexible enough to adjust to \nbudget realities, delivering the type of experience American taxpayers expect and deserve will \nrequire funding. \nScope of the Report \nWith 45 provisions, the Taxpayer First Act refects a wide-ranging effort to improve IRS \noperations. As described below, this report addresses the Act’s three most-sweeping provisions \nrelated to taxpayer service (Section 1101), employee training (Section 2402) and organizational \nstructure (Section 1302).2 Each of these provisions mandates a report to the Congress. \n1\n5\nInternal Revenue Service \| Taxpayer First Act \n1 IRS 2019 Data Book.\n2 Unless otherwise specifed, all Section references herein are to the Taxpayer First Act of 2019, Pub. Law No. 116-25, 133 \nStat. 981 (2019). See Appendix 9.3 for more information about the other TFA provisions, many of which have already been \nimplemented.\n", "16\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\n3 Throughout this report, we use the terms “taxpayer” and “customer” interchangeably. We also refer to the strategy developed \nunder Section 1101 as our Taxpayer Experience Strategy, because the “experience” is the sum of all interactions and includes \nevery touchpoint with a product or service.\n• \nSection 1101, Comprehensive Customer Service Strategy, requires the IRS to develop \na comprehensive customer service strategy that includes best practices similar to those \nprovided by private industry to meet taxpayers’ reasonable expectations, including expanded \nonline services, telephone callback services and employee training. The provision also \nrequires us to assess opportunities to co-locate services with other Federal agencies. \nImportantly, Section 1101 requires that we identify short-term (one to two years), mid-term \n(three to fve years) and long-term (ten years) goals and to develop metrics for measuring \nour progress.3\n• \nSection 2402, Comprehensive Training Strategy, directs the IRS to create a \ncomprehensive training strategy to streamline and improve our current training processes, \ntechnology and funding. Under this provision, our strategy must include annual training \non taxpayer rights with a focus on ensuring that employees can resolve taxpayer issues \nearly, fairly and efficiently. Our strategy must also ensure consistent skill development and \nemployee evaluations throughout the IRS.\n• \nSection 1302, Modernization of IRS Organizational Structure, mandates the IRS develop \nan organizational redesign strategy that prioritizes the taxpayer experience to ensure \ntaxpayers can easily and readily receive the help they need. The strategy will also streamline \nthe structure of the organization and best position the IRS to combat cybersecurity and \nother threats. Finally, Section 1302 requires us to specifcally address whether the current \nIRS Criminal Investigation Division should report directly to the Commissioner. Rather than \nprescribing a particular outcome, Section 1302 gives the IRS the fexibility to determine what \ntype of organizational structure would best serve taxpayers.\nWe consolidated the reports required by Sections 1101, 2402 and 1302, because we believe our \nTaxpayer Experience, Training and Organizational Redesign Strategies are inextricably linked. \nWell-trained employees provide excellent taxpayer service, and a streamlined organizational \nstructure makes it easier for taxpayers and employees to navigate the agency and get help when \nthey need it. \nOur three strategies represent the IRS’s vision and bring the intent of the TFA to life. \nImplementation of the other 42 TFA provisions complements our three strategies. Together, they \nwill bring a game-changing focus to the agency and our workforce. \n", "17\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\n4 Section 3.0 and Section 9.4 provide detailed descriptions of our outreach and research.\nThe Three Strategies \nTo develop our strategies, we conducted in-depth research and devoted months to engaging \nwith a wide array of stakeholders. We listened carefully with an emphasis on lessons learned \nand we strongly considered prior recommendations from our oversight partners.4 As a part of our \ndevelopment process, we developed three overarching goals:\n• \nEnhance the taxpayer experience\n• \nEnhance the employee experience \n• \nImprove operational efficiencies\nOur report further details the objectives and measures that we will use to meet these \nthree goals.\nTaxpayer Experience Strategy \nThe taxpayer experience goes beyond “customer service” to solve a problem. It encompasses \nall taxpayer transactions with the IRS across our service, compliance, and other program areas \nthroughout their lifetime of interactions with the organization.\nIn addition to helping individual and business taxpayers meet their responsibilities and providing \nservices to the tax professionals who represent them, the IRS devotes signifcant resources \nto meeting the special needs of tax-exempt organizations, employee retirement plans and \ngovernment entities in complying with tax laws. These entities, though exempt from federal \nincome tax, rely on IRS services and represent a signifcant aspect of tax administration. \n", "18\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nWith this in mind, we set out to develop a holistic strategy to meet the needs of all taxpayers and \nother entities that rely on the IRS for information and services. Refecting both near-term and \nlong-term goals, our Taxpayer Experience Strategy consists of six components: \n• \nExpanded Digital Services to provide self-service channels by building on existing online \naccounts and introducing online accounts for tax professionals and business taxpayers.\n• \nSeamless Experience to guide taxpayers to the resources and communication channels \nthat will resolve their issues.\n• \nProactive Outreach and Education to educate taxpayers by providing information at the \ntime, in the language, and by the method they prefer through applying behavioral insights, \nusing new technology, and continuing to use and expand upon our trusted partnerships.\n• \nFocused Strategies for Reaching Underserved Communities to consolidate programs \nthat engage with these communities to address communication, education, transparency, \ntrust, and other constraints some face in accessing information and services.\n• \nCommunity of Partners to establish, guide and facilitate a collaborative and interactive \nnetwork of partnerships across and beyond tax administration – including the public, private \nand non-proft sectors – to share best practices and amplify our ability to reach taxpayers \nwith the information they need.\n• \nEnterprise Data Management and Advanced Analytics to develop a data management \nstrategy that includes an agency-wide understanding of the taxpayer experience, emerging \nneeds and expectations, and operational data.\nWe will develop capabilities that are scalable across all taxpayer segments – including individuals, \ndomestic and international businesses, tax exempt organizations, governmental entities, as well as \nour private industry partners and other communities. In this report, we present estimated timelines \n(1-2, 3-5, and 10 years), high-level costing, and measures of success for each component. \nImplementing our Taxpayer Experience Strategy will give taxpayers the information they need to \nunderstand and comply with their taxes. Furthermore, taxpayers will know their feedback has been \nheard. As a result, taxpayers should have more confdence and trust in the IRS. \nSection 4 of this report provides a detailed description of the Taxpayer Experience Strategy.\n", "19\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nTraining Strategy \nWith approximately 75,000 IRS employees assigned to over 500 offices across the nation, \ntraining has never been easy. Effective training and development improves employee \nproductivity, overall job satisfaction and commitment. Additionally, it reduces employee turnover, \ndecreases costly errors and increases overall quality of work. \nOur Training Strategy will strive to improve upon existing training and employee development \nefforts and our unifed approach will enable training to be more relevant and holistic for \nemployees. We will enhance training technology and integrate additional technological tools \nto improve the employee training experience. We will build on previous efforts to develop this \nService-wide approach and include new taxpayer-service concepts into our curriculum. This \nstrategy includes fve components:\n• \nIRS University to serve as an innovative, centralized learning function to improve training \nand encourage collaboration across the organization. The University will build on and unify \nour training and development communities and will feature four academies (Taxpayer \nService, Tax Administration, Information Technology (IT) and Operations Management, and \nLeadership) to organize training curricula around structured yet fexible career paths.\n• \nTaxpayer-First Training to equip all employees with a working knowledge of our Taxpayer \nExperience Strategy, Taxpayer Rights and organizational awareness through a standardized \ncurriculum, while encouraging professionalism, effective communication and empathy. The \nIRS will also emphasize training on civility, inclusive behaviors, cultural competency, taxpayer \nrights and multi-language access. We will integrate new taxpayer-service concepts into \ncurrent training to ensure employees are well equipped to solve taxpayer issues. \n• \nContinuous Learning for All Employees to build on our efforts to provide ongoing \nprofessional training for employees from the frst day on the job throughout their entire career \nwith the organization. A fully realized continuous learning environment will equip employees \nto perform their current role, develop higher levels of technical expertise along a career path \nand support the acquisition of portable skills to allow employees to change roles within \nthe IRS.\n• \nImproving Technology to create accessible, high-quality and effective training programs \nto optimize the employee training experience. We will implement new technology to \naccommodate the administration, delivery and tracking of the training lifecycle. \n• \nMeasuring Success to allow us to make necessary training adjustments and continuously \nimprove our training capabilities.\n", "20\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nBased on our research, we know that employees want to get the most out of their training. They \nrespond well to experienced trainers who are confdent in their feld and adept in engaging in \ntraditional and virtual classroom environments. IRS employees want training that is appropriately \npaced and allows time for practical application. Our comprehensive Training Strategy is intended \nto create an environment where employees receive timely training, have access to personal \ndevelopment resources and are equipped with the skills necessary to identify opportunities to \nenhance taxpayer service. \nAs explained in this report, we aligned our Training Strategy with our Taxpayer Experience \nand Organizational Redesign Strategies to create a continuous learning environment for our \nemployees. \nSection 5 of this report provides a detailed description of the Training Strategy. \nOrganizational Redesign Strategy \nWhile our current organizational model was, and is, effective in many areas, we recognize that \nchanging times call for new ways of doing business for taxpayers and IRS employees. As the \nfrst high-level restructuring plan in more than 20 years, our Organizational Redesign Strategy \nconsiders areas of success and opportunities for improvement. We will capitalize on our \nstrengths and make structural changes where needed to better serve taxpayers. \nAs mandated by Section 1302, the IRS built \non previous strategic initiatives and insights, \nstudied industry and global revenue agency \ntrends and best practices, and assessed \nevolving taxpayer expectations. Through careful \nresearch of oversight recommendations, \ntaxpayer insights and employee interviews, \nwe identifed efficiencies and eliminated \nredundancies, while ensuring leadership \naccountability for key components of the \ntaxpayer experience and employee training. \nOur new organizational structure will increase \nagency-wide collaboration and deconstruct \noperational silos, thereby improving our ability \nto provide seamless service to our employees \nand taxpayers. By design, our new structure \nfully supports our Taxpayer Experience and \nTraining Strategies.\nThis belongs to you; it belongs \nto your clients; it belongs to every \nperson in the IRS workforce, \nand we want to get it right.\n— Charles Rettig, IRS Commissioner\n", "21\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nOur Organizational Redesign Strategy focuses on the following key areas: \n• \nImprove Integration of Strategic Planning and Initiative Prioritization at the Enterprise \nLevel\n• \nCreate a new Enterprise Change and Innovation Division that would serve as \nthe IRS’s “strategic integrator”\n. This division would work with leadership across \nthe agency to coordinate annual strategic planning and prioritization activities to \nstreamline decision making and enable the agency to set and meet its short and \nlong-term strategic goals.\n• \nThe Enterprise Change and Innovation Division would pull together the Taxpayer \nExperience, Training, and Organizational Redesign Strategies described in this \nreport as well as other work on strategic direction (e.g., The Modernization plan; \nthe Enterprise Case Management and Digitalization strategies; and future-focused \nefforts being led by our Human Capital and Equity Diversity and Inclusion offices) to \nperpetuate an integrated, collaborative, agency level strategic direction.\n• \nImprove the Taxpayer Experience and Provide a Continued Emphasis on Taxpayer \nRights\n• \nCreate a new senior position for a Chief Taxpayer Experience Officer, who will seek \nto drive strategic direction for improving the taxpayer experience across the IRS-\nincluding both service and compliance interactions. \n• \nIntegrate taxpayer experience related strategies and initiatives with other \nagency priorities.\n• \nProvide an enterprise level holistic view of the taxpayer experience, identify \nopportunities in existing taxpayer-facing processes and drive continuous \nimprovements in real time. \n• \nCombine and centralize taxpayer-facing program offices to streamline responses to \ntaxpayer inquiries and increase coordination across the agency.\n• \nIntegrate IRS services and communication channels to facilitate a more seamless \nand holistic taxpayer experience.\n• \nCreate a smaller, taxpayer-focused Senior Leadership Team5 led by the \nCommissioner to ensure that taxpayer rights are foremost in our long-term planning \nactivities.\n5 In the new organizational structure, the Senior Leadership Team will serve in place of the current Senior Executive Team. \nWhile the total number of direct reports to the Commissioner is increasing under this organizational structure, the Senior \nLeadership Team will be signifcantly reduced.\n", "22\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\n• \nImprove Operational Efficiencies\n• \nConsolidate previously segmented examination operations into one function to \nreduce internal duplication and fragmentation of activities and provide consistent \noutcomes for resolving taxpayer compliance issues.\n• \nCreate a new Relationships and Services Division that operationalizes the taxpayer \nexperience and:\n• \nConsolidates all toll-free telephone and taxpayer assistance center operations \nunder one, “\nAssisted Services” organization.\n• \nCombines all outreach activities under one organization.\n• \nCombines all third-party partnership activities within one division.\n• \nCreate a Data Office and an Enterprise Digitalization and Case Management Office \nthat will improve our use of data to reduce manual processes and reliance on paper \nwhile improving compliance operations and taxpayer service initiatives.\n• \nIncrease Collaboration\n• \nFlatten and streamline the headquarters executive leadership structure to increase \ncollaboration and continuity in decision making.\n• \nProvide the Commissioner with a more direct line of sight into operations and \nfunctions.\n• \nEnhance Innovation\n• \nEstablish a direct line from the Commissioner to the Information Technology Division \nto enhance critical focus on cutting-edge business processes and technology.\n• \nContinue our emphasis on innovation in existing offices that are already driving or \nenabling creative taxpayer approaches across the IRS, such as Procurement and \nInformation Technology, to build an even more innovative culture throughout the \norganization.\n• \nContinue to Improve Critical Operations Currently Serving Taxpayers Well\n• \nFocus on individualized service to combat identity theft through strong identity theft \nand victim assistance efforts.\n• \nSupport the vital efforts of the Whistleblower Office.\n• \nMaintain an effective Criminal Investigation Office to drive an enforcement presence \naligned to other compliance offices for continued coordination and emphasis.\n• \nDeliver fling season services by continuing the successful fling season Executive \nSteering Committee approach while gaining efficiencies through close coordination \nbetween our Information Technology Division and the new Relationships and \nServices Division.\n", "23\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nFigure 1: Notional Future IRS Organizational Structure\nThe IRS Organizational Structure as of September 2020 can be found in Section 6.1. Under \nthe new structure, shown in Figure 1, the Commissioner would be supported by a Deputy \nCommissioner, a Chief of Staff and ten direct reports. This team would work together to set the \ndirection of the agency, empower the workforce, enhance innovation and improve the taxpayer \nexperience. \nKey Features and Benefits of the New Organizational Structure\n", "24\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nThe new Chief Taxpayer Experience Officer (CTXO) would drive strategic direction for \nimproving the taxpayer experience across the IRS and would help ensure a consistent voice \nand experience across all taxpayer segments by developing agency-wide taxpayer experience \nguidelines and expectations. Collaborating with peers across the entire agency, the Chief \nTaxpayer Experience Officer would drive an enterprise-level holistic view of the taxpayer \nexperience. Working closely with the Relationships and Services and Compliance Divisions - \nwhich will be the originating source for most taxpayer interactions, and the Enterprise Change \nand Innovation Office (ECIO) - the “strategic integrator”\n, the Chief Taxpayer Experience Officer \nwould drive continuous improvement across the service delivery operations. The Chief Taxpayer \nExperience Officer’s close collaboration with the ECIO would ensure that Taxpayer Experience \nStrategies align with overarching enterprise priorities and any key legislative initiatives. The \nChief Taxpayer Experience Officer would also seek to drive consistency across many different \nareas, including working within the Relationships and Services Division, Compliance Division, \nIRS Independent Office of Appeals and Office of Chief Counsel to facilitate the use of new tools \nfor communicating with taxpayers and their representatives. We envision the Chief Taxpayer \nExperience Officer as a subject matter expert with the ability to provide other organizational units \nwith information on changing taxpayer expectations, industry trends and ways to apply customer \nservice best practices within the framework of IRS operations and federal limitations. This \nenterprise-wide approach to the taxpayer experience will ensure that taxpayer-facing capabilities \nare developed and deployed in a way that is scalable and usable across all interactions and \nnot for single purpose/single use/single program area. The Taxpayer Experience Office (TXO) \nwill also identify opportunities in existing taxpayer-facing processes and drive continuous \nimprovements in real time. This office would help to eliminate systemic breakdowns before they \ncan have a negative impact on taxpayers. \nThe new Relationships and Services Division would bring together all taxpayer-facing service \nactivities, serving as the front door to the IRS for all taxpayers and stakeholders. This division \nwould deliver services and information to America’s taxpayers through a variety of channels – \nincluding telephone, digital, correspondence, social media and face-to-face (both in-person and \nthrough virtual technology). While the Chief Taxpayer Experience Officer would be responsible \nfor developing and continuously evolving the Taxpayer Experience Strategy, the Assistant \nCommissioner of Relationships and Services would work with the Chief Taxpayer Experience \nOfficer and Enterprise Change and Innovation Division to execute on the vision of the Taxpayer \nExperience Strategy. With all taxpayer-facing service channels under a single umbrella, this \nstructure would create one division responsible for end-to-end service delivery and relationship \nmanagement, while sustaining the value of having some aspect of taxpayer segmentation \nand specialization within the program areas. This structure would integrate channels and \nfacilitate easier navigation of the IRS enabling a more seamless experience for taxpayers and \nstakeholders.\n", "25\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nThe new Compliance Division would consolidate compliance functions across taxpayer \nsegments into one division and establish an enterprise-level Chief Compliance Officer. This \nchange would facilitate the development of a consolidated compliance strategy that considers \nemerging issues across all taxpayer segments and enables Exam and Collection leadership to \nidentify cross-cutting behavioral trends. This coordination would reduce variability in compliance \nprocesses and, working with the Chief Taxpayer Experience Officer, provide a more consistent \ntaxpayer experience across all taxpayer interactions. Ultimately, this consolidation aims to reduce \nduplicative activities related to strategic planning, issue identifcation, work plan development, \ncase selection, performance monitoring, and research. Coupled with our Training Strategy, this \nstructure would create more complete and connected career paths for IRS employees.\nThe new Enterprise Change and Innovation Division would serve as a “strategic integrator,” \nresponsible for planning and overseeing the implementation of enterprise-wide initiatives. The \nAssistant Commissioner of the Enterprise Change and Innovation Division would work with \nleadership across the agency to coordinate annual strategic planning and prioritization activities \nto streamline decision making and enable the agency to set and meet its short and long-term \nstrategic goals. Most immediately, the Strategic Planning and Legislative Implementation \nOffice (SPLIO) within this division would coordinate the implementation of the TFA strategies \n(Taxpayer Experience, Training, and Organizational Redesign) through program management, \ngovernance, change management and other tactical implementation functions. SPLIO would \npartner closely with the Taxpayer Experience Office and the Relationships and Services \nDivision on implementing the Taxpayer Experience Strategy, and with the Human Capital Office \non implementing the Training Strategy. As strategic integrator, this office would bring together \nthese and other discrete strategies developed across the IRS into an enterprise integrated \nstrategy which would be leveraged by IRS Senior Leadership to identify and drive prioritization \nof investments. While SPLIO would be responsible for implementing TFA legislation, it would \nhave the capabilities in place to effectively transition to leading other signifcant legislative \nimplementations or enterprise level strategic initiatives as they arise. This would enable the \nIRS to strategically address legislative changes, standardize execution and coordinate with the \nappropriate operating divisions. \nThe Chief Data Officer will be part of the Enterprise Change and Innovation Division. \nWorking closely with his or her peers across the agency, the Chief Data Officer will develop \nan enterprise-wide data strategy and oversee all activities related to data and data analytics. \nThis data strategy will provide the IRS with a framework to assess, prioritize, and address \ndata access and analytics needs across the IRS and to guide program and policy decisions. \nThe Chief Data Officer will also incorporate new evidence building processes needed to make \nbetter decisions to meet the changing needs and expectations of taxpayers as well as ensure \nstrategic planning business decisions are data driven and in line with documented organizational \nchallenges and risks. The Chief Data Officer will be instrumental in the implementation of the \nData Management and Advanced Analytics aspect of the Taxpayer Experience Strategy and \n", "26\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nwill support the Enterprise Case Management and Digitalization strategies. Improved data \nmanagement and analytics will feed improvements to the Compliance and Relationships and \nServices divisions.\nThe Operations Management Division will be a revitalized support structure that will help \nthe agency address many of the challenges we face in today’s current tax administration \nenvironment. Their work will include a focus on delivering internal operations and facilitating \ndelivery of taxpayer and external stakeholder facing programs. Operations Management links \nvarious functions throughout the organization, ensuring a smooth fow of information and ease of \ninternal and workforce operations. This division will be comprised of many of the critical existing \nsupport functions within Operations Support’s current structure. The newly designed Operations \nManagement Division will support critical day-to-day IRS operations, enabling other functions \nwithin the organization to increase their focus on taxpayer service. Operations Management will \ninclude the Diversity Office and the Risk Office. Due to their critical roles, the Diversity Office and \nRisk Offices will also have dotted line6 direct reporting relationships to the IRS Commissioner.\nThe Assistant Commissioner Chief Information Officer will oversee the Information \nTechnology Division and will regularly interface across the IRS to understand its technology \nneeds. The Information Technology Division will be responsible for coordinating and leading \nfocused initiatives on technology (e.g., Strategic Oversight, Enterprise Development, Cyber, \nEnterprise Operations, Computing Centers, User and Networks Service, Enterprise Architecture \nand Engineering, and Program Modernization) in order to better respond to taxpayer demand \nfor innovative information technology solutions and online services. This division will be \nresponsible for all IT services and will retain a similar operational structure to the existing IT \nDivision, including the Cybersecurity Office. However, the Cybersecurity Office will be expanded \nto incorporate the various cybersecurity activities across the agency. By aligning the Information \nTechnology Division as a direct report to the Commissioner, it better enables earlier awareness \nand more rapid response to critical emerging technology issues. This structure will also increase \ncollaboration with peer direct reports to address enterprise priorities and better align with our \nmodernization efforts.\nThis report also addresses the alignment of structural changes with oversight recommendations \nand the positioning of the IRS Criminal Investigation Office.\nAdditional Considerations for the Organizational Redesign Strategy \nThe Organizational Redesign Strategy also addresses changes to our governance structure, \nappropriations allocation, policy and legislation, and working relationships with our oversight \nand advisory partners. By modernizing our structure to increase collaboration, combine \nsimilar operations and support our employees throughout their careers, we will transform \n6 For daily operations, offices with dotted line reporting to the Commissioner, will report to their leadership but will have direct \naccess to provide regular updates and guidance to the Commissioner. These offices will also serve in advisory roles to the \nSenior Leadership Team. \n", "27\nInternal Revenue Service \| Taxpayer First Act \n2.0 \| EXECUTIVE SUMMARY\nboth the taxpayer experience and our internal operations. Knowing that a restructuring of this \nscale cannot be realized overnight, we will take a multi-year approach to implementing our \nOrganizational Redesign Strategy. We are committed to short-term, mid-range and longer-term \nimprovements; however, we note that signifcant and long-term changes depend on continuous \ninvestment as well as legislative and policy changes. We envision dedicating FY2021 to \ndeveloping an Organizational Blueprint Report that includes a detailed roadmap and project plan \nfor restructuring the organization. Our Organizational Blueprint Report will further defne the role \nand structure of key offices in our future organizational structure as well as an updated operating \nmodel. Lastly, we envision using FY2021 to establish and fll key new positions (e.g. Chief \nTaxpayer Experience Officer) and make initial organizational changes. The divisions and offices \noutlined in this report may change as we continue to refne our organizational structure. \nSection 6 of this report provides a detailed description of the Organizational Redesign Strategy. \nImplementation of the Taxpayer Experience, Training and Organizational Redesign \nStrategies \nWe designed our strategies to be fexible depending on fscal realities. Our implementation plans \nprioritize the tools, training and structure we need to ft within the funding we receive. This report \nwill also illustrate how the IRS is already implementing some aspects of each strategy. \nSection 7 of this report provides a detailed description of additional key considerations for the \nimplementation of our proposed strategies. In particular, it summarizes the estimated notional \ncosts over five years of $2.\u0013 billion in order to put this plan in place.\nReimagining our organizational structure to place key organizations and Senior Leadership \nTeam members with direct alignment to the Commissioner will strengthen the IRS’s ability to \ndrive agency priorities and executive accountability on future initiatives while administering the \ntax code. The internal policies we identiﬁed under the direction of former Commissioner Larry \nGibbs (serving from 1986-1989) established that, “The Internal Revenue Service be a progressive \norganization...and will be so administered to provide vigorous and dedicated attention to making \nthe Internal Revenue Service a truly forward thinking organization.” (Policy Statement 1-21). Our \ncurrent policy statement and future activities underscore the relevance of this thinking even today. \n\| WHAT WE HEARD \| \n", "28\nInternal Revenue Service \| Taxpayer First Act\nS E C T I O N3\nInternal Revenue Service \| Taxpayer First Act \nOUR\nAPPROACH\nInternal Revenue Service \| Taxpayer First Act \n", "3.0 \| OUR APPROACH\n2\n9\nInternal Revenue Service \| Taxpayer First Act \n29\nInternal Revenue Service \| Taxpayer First Act\n3.0 \nOUR APPROACH\nThe Commissioner assigned a team of executives to launch and lead a Taxpayer First Act Office \n(TFAO) shortly after the TFA became law. The TFAO sits within the Commissioner’s Office of \nChief of Staff and coordinates agency-wide implementation of all TFA provisions. For the past \nyear and a half, the TFAO has led the integration of TFA-related communications, program \nmanagement and governance. With input from IRS senior leaders, employees and other \nstakeholders, the TFAO also spear-headed development of our Taxpayer Experience Strategy \n(Section 1101), Training Strategy (Section 2402) and Organizational Redesign Strategy (Section \n1302). The TFAO executives identifed emerging IRS leaders and additional staff to support this \nwork.\nProgram planning for the office included developing a vision statement, a set of guiding \nprinciples and a timeline. \nVision Statement: \nWorking collaboratively, the Taxpayer First Act Office will reimagine our organization to enable an \nagency-wide focus on providing a high-quality taxpayer experience for all.\nGuiding Principles: \nAs we pursue our mission and vision with honesty and integrity, we will:\n• \nCoordinate and integrate.\n• \nListen, learn and then design.\n• \nBuild excitement through regular and transparent communications.\n• \nEmbrace accountability through results.\n", "3.0 \| OUR APPROACH\n3\n0\nInternal Revenue Service \| Taxpayer First Act \n30\nInternal Revenue Service \| Taxpayer First Act\nThe listen, learn and then design principle was particularly powerful in guiding our work: \n• \nListen: We approached this effort without preconceived notions of what our stakeholders \nexpect from the IRS. We dedicated the frst four months to conducting listening sessions \nacross the country and around the globe, engaging a wide variety of stakeholders inside and \noutside of our organization.7\n• \nLearn: Across all three strategies we reviewed extensive documentation including existing \nresearch studies, customer satisfaction results, business data, peer agency best practices \nand private sector industry best practices. \n• \nDesign: We committed to designing a comprehensive Taxpayer Experience Strategy, \nTraining Strategy and Organizational Redesign Strategy that would best position the agency \nto put taxpayers frst. We based our design on what we learned from our listening sessions, \nresearch and feedback. \nPutting taxpayers frst requires understanding taxpayer perspectives as well as the perspectives \nof members of the tax community, such as tax professionals and tax software developers. We \ngathered feedback from a wide range of stakeholders to develop comprehensive strategies. \nOur outreach included town halls, focus groups, internal and external interviews and forums \nwith stakeholders across tax administration. We held more than 150 events to collect feedback, \nrecommendations, solutions and to better understand common areas of concern. We established \nelectronic mailboxes to receive input directly from employees, taxpayers and other stakeholders. \nWe analyzed more than 1,000 pieces of correspondence through these inboxes. In addition, we \ncommunicated directly with internal and external stakeholders to answer questions related to the \nTaxpayer First Act. \nInternally, we engaged employees, management and senior executives from across the agency. \nExternally, we engaged a wide range of stakeholders to ensure we obtained a comprehensive \nview of taxpayers’ unique needs. This included taxpayers; partners; self-employed individuals; \nsmall, large and international businesses, tax exempt entities; advisory groups; industry groups; \noversight organizations and other government agencies. We also coordinated periodically with \nthe Office of Management and Budget (OMB), the Department of Treasury and the Congress \nthroughout the development process. We will maintain open lines of communication with our \noversight partners as we continue to implement the strategies outlined in this report. \n7 See Section 9.4 for full list of stakeholders who provided feedback.\n", "3.0 \| OUR APPROACH\n3\n1\nInternal Revenue Service \| Taxpayer First Act \n31\nInternal Revenue Service \| Taxpayer First Act\nIn developing its \nTaxpayer Experience Strategy \nand Organizational Redesign Plans, \nthe TFAO has been listening \nto a wide array of internal and \nexternal stakeholders \nincluding tax professionals, \nIRS leadership, IRS employees, \nand the National Treasury \nEmployees Union.\n— National Taxpayer Advocate\nAs part of our research and analysis, we \nexamined numerous research studies, \nthird-party research articles, industry best \npractices, as well as results from 61 different \ncustomer satisfaction surveys. Additionally, \nwe considered recommendations from \noversight reports, including the U.S. \nGovernment Accountability Office (GAO), \nthe U.S. Treasury Inspector General for Tax \nAdministration (TIGTA) and the National \nTaxpayer Advocate (NTA) and related case \nstudies. Throughout the process, we ensured \nour strategies aligned with and supported the \nTaxpayer Bill of Rights.\nBased on what we learned, we identifed \nkey insights and opportunities that serve \nas the foundation for our strategies. This \ncomprehensive approach allowed us to \ndevelop the Taxpayer Experience Strategy, \nTraining Strategy and Organizational \nRedesign Strategy based on the needs and \nconcerns of our stakeholders. \n", "3.0 \| OUR APPROACH\n3\n2\nInternal Revenue Service \| Taxpayer First Act \n32\nInternal Revenue Service \| Taxpayer First Act\nFor details about our methodology, engagement activities and research, please refer to the \nMethodology Section 9.1. \nFigure 2: TFAO Methodology\n", "33\nInternal Revenue Service \| Taxpayer First Act\nS E C T I O N4\nInternal Revenue Service \| Taxpayer First Act \nTAXPAYER \nEXPERIENCE\nSTRATEGY\nInternal Revenue Service \| Taxpayer First Act \n", "34\nInternal Revenue Service \| Taxpayer First Act\nThe taxpayer experience is the cornerstone of \nour mission. A positive experience increases \ntrust in government and promotes voluntary \ntax compliance. During listening sessions, we \nlearned that taxpayers and other stakeholders \nappreciate the service IRS employees provide, \nbut they want more consistency and access to \na wider range of services. Through interactions \nwith online retailers, banks and other businesses, \nthe public has come to expect top-notch service, \ntechnological solutions and personalized \ncommunications from organizations. Similarly, \ntaxpayers expect the IRS to provide convenient \naccess to easy-to-understand information when \nthey need it. \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n4.1 INTRODUCTION AND \nEXPLANATION OF STRATEGY\n3\n4\nInternal Revenue Service \| Taxpayer First Act \n”\nWe must modernize our service and compliance models to meet taxpayer expectations. \nWe have developed a strategy in which interactions with the IRS are efficient, informative, \npersonalized and convenient. We are putting taxpayers frst while ensuring fairness and \ncompliance with the tax law. \n", "35\nInternal Revenue Service \| Taxpayer First Act\n4.1 STRATEGY OVERVIEW\nExpanded Digital Services to improve online experience for all taxpayers and authorized tax \nprofessionals. This includes enhancing the IRS’s online accounts for individual taxpayers and \nexpanding this service to tax professionals and businesses. Research shows that promoting \nthe use of self-service channels along with the use of plain language has increased voluntary \ncompliance and decreased phone calls. \nSeamless Experience to provide taxpayers with their preferred channel of service (website, \ntelephone, in person, etc.) and integrate those channels to seamlessly guide them to the help \nthey need throughout the taxpayer lifecycle. IRS employees should be trained and empowered \nto resolve issues in a timely manner and will guide taxpayers to resources or to another IRS \nemployee as appropriate. By increasing organizational awareness, integrating channels, \nreducing wait times and streamlining taxpayer service we increase the likelihood of taxpayer’s \nissues being resolved, which research shows improves compliance.8 \nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n8 The 2019 Comprehensive Taxpayer Attitude Survey found, on average, that taxpayers are willing to wait approximately 15 \nminutes on hold when using the phone.\nTo transform how we operate, we reimagined the taxpayer experience across six areas of focus: \nWe heard from external \nstakeholders – and our own \nemployees – that it is hard to navigate \nthe IRS. Tax administration is too \nbroad and complex for us to ever train \nour employees to handle every issue \nthat could come up, so we must focus \non increasing their organizational \nawareness and equipping them with \nthe tools to shepherd taxpayers \nto resolution.\n— James Clifford, TFAO Executive\nProactive Outreach and Education to \nimprove how and when we provide information \nto taxpayers by using new technology, \napplying behavioral insights, expanding our \nsocial media strategy and making use of our \ntrusted partnerships. We should communicate \nwith (and be open to receiving communication \nfrom) taxpayers at times that are convenient \nto them, in a multitude of languages, and by \nthe method they prefer. Educating taxpayers \nwill serve to increase taxpayer confdence in \nmeeting their tax obligations and decrease the \nlikelihood that they will encounter compliance \nissues or need to contact the IRS. Accelerated \noutreach allows taxpayers to resolve issues \nand balances before the penalties and interest \nmake these balances too large for taxpayers to \neffectively manage. \n", "36\n4.1 STRATEGY OVERVIEW\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nCommunity of Partners to build on our existing \nrelationships and develop new partnerships to \ncreate an integrated delivery network of trusted \npartners across the tax community. Trusted \npartnerships will encourage the sharing of \nperspectives and best practices and provide \na forum to discuss innovative ideas and \napproaches for working with a diverse range \nof customer segments. The Community of \nPartners will support the Focused Strategies \nfor Reaching Underserved Communities. \nLeveraging partnerships with those who already \nhave established relationships and networks \nin hard to reach communities can amplify our \nmessaging by providing IRS content via a trusted \nvoice in communities. This approach already \ndelivers benefts. For example, each year the IRS \nleverages partnerships with Volunteer Income \nTax Assistance organizations whose programs and volunteers prepare 3.6 million returns for \ntaxpayers with the support of only about 400 IRS employees.\nFocused Strategies for Reaching Underserved Communities to build on existing successes \nand establish specifc strategies to engage with underserved communities to address issues \nof communication, education, transparency, trust, and access to quality products and services. \nWe understand that some segments of the taxpayer population face unique obstacles to getting \naccess to the information and services needed to comply with their tax obligations. To address \nthe needs of these communities, the IRS should provide customized education and outreach \nin the languages spoken by specifc taxpayer groups. As shown by the Earned Income Tax \nCredit (EITC) Underserved Outreach Project,9 developing specifc strategies for underserved \ncommunities is crucial to increasing their participation. This project identifed individuals who \nwere likely eligible to claim the EITC but did not fle returns. The 2014 study showed that \nindividuals who received outreach through the mail increased fling rates for current and prior-\nyear returns by roughly 0.5% to 1%. The study resulted in 53,000 additional flers with $180 \nmillion in additional refunds. \n9 Inattention and Tax Benefts: Third-Party Reporting and IRS Outreach to Low-Income Nonflers Research Project – \nconducted by Research, Analysis & Statistics Division in IRS Office of Research.\n", "37\nInternal Revenue Service \| Taxpayer First Act\n4.1 STRATEGY OVERVIEW\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nEnterprise Data Management and Advanced Analytics to develop a secure data \nmanagement strategy that includes an agency-wide understanding of administrative data, the \nability to integrate operational, employee, and customer feedback data, and analyze that data \nto pinpoint specifc improvements to reduce costs and improve the taxpayer experience. In \naddition, new technology applied in a responsible and ethical manner, such as chat bot tools \npowered by artifcial intelligence (AI), can enable ongoing, real-time learning from taxpayer \nneeds and ultimate compliance actions, further improving both the taxpayer experience and \ndelivery of our mission. Applying advanced analytics will help us better understand taxpayer \nbehavior to determine the most meaningful offerings to support the taxpayer experience. \nEvery IRS employee is a \ncustomer service officer. \nEvery interaction is important.\n—Charles Rettig, Commissioner\nThis strategy is not a series of discrete \napproaches, but rather integrated strategies that \nbuild on each other to create the best holistic \nexperience for the greatest number of taxpayers. \nWhen woven together, and supported by the \nTraining and Organizational Redesign Strategies, \nthe Taxpayer Experience Strategy creates a \ncomprehensive taxpayer experience in which \ninteractions with the IRS are efficient, informative, \npersonalized and convenient. The results of this \nstrategy will ensure our stakeholders know that \ntheir feedback was heard and valued, increasing \ntrust between the IRS and taxpayers. The fve-year cost of the Taxpayer Experience Strategy is \nestimated at approximately $1.2B. Details can be found in Section 9.5.2.1.\nThe following Sections describe each component of the strategy in detail. For each, we present \nthe capabilities that will provide value to taxpayers, high-level costs, measures of success and \nan estimated timeline for phased implementation over one to two, three to fve and ten years. \nWhere applicable, we also share examples of how we are already using some capabilities \nto improve the taxpayer experience. For instance, IRS efforts to adapt to and address the \nCOVID-19 emergency provide a real-time opportunity to test and evaluate some aspects of our \nTaxpayer Experience Strategy. \nSee the Appendix 9.6, for more information about the strategic goals and underlying objectives \nthat provide the framework for our Taxpayer Experience Strategy, including alignment with other \nIRS strategies, such as the Integrated Modernization Business Plan.\n", "38\nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n4.2 MEASURING SUCCESS\nTo measure the success of the Taxpayer Experience Strategy, we developed a tiered framework. \nBy gathering and analyzing data associated with these measures, the IRS will be able to \nevaluate the progress of this strategy and assess the degree of success in offering new or \nenhanced capabilities. We also identifed three measures that collectively assess the degree of \nsuccess of implementing the Taxpayer Experience Strategy as a whole.\nThe Taxpayer Experience Strategy measures are built on a tiered step framework in Figure 3, \nwhich includes “\nAccess” measures, “\nAdoption” measures, and “Impact” measures.\nFigure 3: T\naxpayer Experience Tiered Step Framework\n", "39\nInternal Revenue Service \| Taxpayer First Act\n4.2 MEASURING SUCCESS\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nThis framework will allow us to track the \neffectiveness of the strategy in real-time – are we \nhaving the intended impact? Are taxpayers adopting \nthe options we invest in? What drivers are most \nimportant to our taxpayers’ experiences? Does the \nway we’re implementing our strategy need to be \nadjusted? This robust suite of measures will inform \nour decision-making, and the Sections that follow \neach include measures to help us answer these \nquestions. While we have aligned measures to each \ncomponent of the strategy, we also developed three \nmeasures (see below) that will help us determine \nthe success of the Taxpayer Experience Strategy as \na whole. \nTIER\nWHAT WE ARE TRYING \nTO MEASURE\nMEASURE / INDICATOR \nBASELINE\nTARGET / PROJECTION\nImpact / Outcome\nIncrease trust and confdence \namong taxpayers interacting \nwith the IRS\nComprehensive Taxpayer \nAttitude Survey (CTAS): I \ntrust the IRS to help me \nunderstand my tax obligations\n70% (FY2019)\nIncrease to 72% by FY2022\nImpact / Outcome\nSatisfaction with IRS \ninteractions\nCTAS: The percentage of \ntaxpayers satisfed with their \npersonal interactions with \nthe IRS \n77% (FY2019)\nIncrease to 79% by FY2022\nImpact / Outcome\nTime to resolve your issue \nwith the IRS\nTaxpayer Experience Survey \n(TES): How satisfed were you \nwith the time it took to resolve \nyour issue?\n73% (FY2019)\nIncrease to 75% by FY2022\nThe IRS is an investment that \nwill pay back. Investing in better \ncustomer service will result in \nbetter compliance.\n—John Koskinen, Former IRS Commissioner\nAt its highest level, this framework will help assess how the Taxpayer Experience Strategy \nimpacts voluntary compliance. However, given the time it takes to accurately measure voluntary \ncompliance, the framework relies on intermediary outcome measures like trust and confdence \nand taxpayer satisfaction as a proxy for improving voluntary compliance. Measures will be \nreported annually and will include baselines, targets (as appropriate)10 – or projections, and \nsources, for a given fscal year. Some of these measures are new to the IRS, and for those we \nlay out a timetable for designing, testing and baselining them. \n10 In some cases, it is more effective to simply monitor a measure rather than set targets that could encourage unintentional \nbehaviors or results. For example, while it is useful to track the usage of a call back feature, we would not want to set a target \nto increase the use of that feature since that would be a direct result from increased wait times.\n", "40\nInternal Revenue Service \| Taxpayer First Act\n4.2 MEASURING SUCCESS\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nThe 2018 President’s Management Agenda lays out a long-term vision for modernizing the \nFederal Government in key areas that will improve the ability to deliver mission outcomes, \nprovide excellent service, and effectively steward taxpayer dollars on behalf of the American \npeople. The Taxpayer Experience Strategy aims to align to the recent Presidential Management \nAgenda by enhancing customer service, establishing new relationships with our diverse set of \npartners, expanding existing digital capabilities, and developing new taxpayer experience tools \nand technology that compares to or exceed that of other Federal agencies and private industry. \nThe suite of taxpayer experience measures will continue to evolve as the Taxpayer Experience \nStrategy progresses and our performance management process matures. We will continue to \nrefne these measures and identify new measures that will best inform our efforts to continually \nimprove and enhance the taxpayer experience. To a signifcant degree, our future work on \nmeasuring the taxpayer experience will be informed by repeating the listening and learning \ncampaigns employed as part of our work to develop the Taxpayer Experience Strategy and \nthrough, the Continuous Feedback Loops and Community of Partners we deploy as part of this \nstrategy. \n", "We will expand digital services through secure online accounts and other paperless initiatives. \nOur goal is to empower taxpayers to resolve certain issues themselves before contacting the \nIRS. To do this, we must make sure taxpayers have the digital tools they need. Many taxpayers \nwill be familiar and comfortable with this type of interaction due to similar services provided by \nbanks and other private sector organizations. However, we continue to recognize the need to \nhave some non-digital options, such as phone and paper, to be available for accessibility.\nIRS online accounts are a digital portal for taxpayers to securely access their tax information, \nmake changes to their personal information, and communicate with the IRS online. As part of \nour Taxpayer Experience Strategy, we will improve the secure online accounts currently avail-\nable for individual taxpayers and make similar online accounts available for businesses and tax \nprofessionals. The IRS will continue to apply the highest security standards to online accounts \nto protect taxpayer information, but we will also continue to make some self-service digital tools, \nsuch as online payments, available to taxpayers unable to meet identification verification and \nauthentication requirements. Whether through a computer, tablet, or mobile phone, access to \nonline accounts and digital self-service tools will provide a more convenient and efficient taxpay-\ner experience. Customer feedback data across government has already showed increased satis-\nfaction rates with Federal online services when users are logged into a personalized account. \nThe following key capabilities form the basis of Expanded Digital Services— \n•\nExpand Individual Online Accounts:\n•\nSecure Two-Way Messaging: Give taxpayers the ability to communicate with IRS\nemployees through their online accounts.\n•\nTaxpayer View History: Allow taxpayers to see information about their tax histories\n(such as refunds, payments received, amounts owed, returns fled, etc.) through their\nonline accounts to ensure transparency and accessibility of records.\n•\nChange Account Information (“Self-Correct Entity”): Allow taxpayers to update\ncontact information and other key details.\n•\nDigital Notifcations: Generate customized taxpayer notices and letters accessible\nthrough online accounts. Taxpayers will be able to opt in to receive personalized\nnotifcations about changes to their tax situation, payment reminders and status\nupdates on refunds or audits. This capability also supports Proactive Outreach and\nEducation.\n41\nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n4.3 EXPANDED DIGITAL SERVICES\n", "• \nBusiness Online Account: Provide online accounts and services for businesses. \n• \nTax Professional Online Accounts: Provide online accounts for tax professionals, which \nallows eligible representatives to access client information and services. \n• \nExpand Payment Options: Provide taxpayers, businesses and tax professionals the ability to \nmake payments through all channels including telephone, online accounts, mobile apps and \nwalk-in assistance. Electronic funds transfer (EFT) and credit and debit cards interactions will \nremain available as well.\n42\n4.3 EXPANDED DIGITAL SERVICES\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n11 The IRS established the Secure Access Digital Identity initiative to satisfy digital identity guidelines released by the National \nInstitute of Standards and Technology. These guidelines apply to all federal agencies implementing digital identity services.\n• \nSecure Document Exchange: Allow taxpayers, businesses, tax \nprofessionals and IRS employees to securely upload and access \ndocuments in a centralized repository. \n• \nDigital Signatures: Allow authenticated individual taxpayers \nand representatives to submit electronic signatures via online \naccounts.\nThe IRS has already implemented several electronic tools and \npaperless initiatives. For example, when the IRS began to scale \nback operations in March 2020 due to the COVID-19 pandemic, \ncritical work could not continue without a way to securely and virtually \ncommunicate with taxpayers. The IRS Information Technology \nDivision quickly provided secure email capabilities with an attachment \nfeature that enabled taxpayer services and compliance case activities \nto continue. By the frst week of April, the IRS procured and expanded \nlicenses to support up to 6,000 IRS users, while simultaneously \nimplementing enhanced security and operational requirements. \nIn addition, the IRS Non-Filers’ online tool, developed to support \ntaxpayers during the COVID-19 pandemic, remains available to help \ntaxpayers sign up for Economic Impact Payments (EIP). \nWhile we work to enhance existing tools and take additional steps toward an electronic \nenvironment, we understand that security must remain the foundation of our efforts. The IRS \nestablished an integrated Enterprise Case Management (ECM) and Digitalization function to take \nsteps toward integrating these tools. Through the Secure Access Digital Identity Initiative,\n11 we \ncontinue to improve identity verifcation and authentication to reduce fraud and identity theft. In our \nefforts to ensure taxpayer information is protected, we must employ stringent security standards. \nHowever, data shows that not all taxpayers can pass these stringent standards and this may limit \naccess to IRS online accounts for some taxpayers.\nImage of Free T\nax Help page on \nIRS2Go app\n", "43\nInternal Revenue Service \| Taxpayer First Act\n43\nInternal Revenue Service \| Taxpayer First Act\nProvide Clear and Timely \nCommunications \nIncrease Access and Promote \nTransparency\nSimplify the Tax Process\nOBJECTIVES\nUnderstand, Inform and \nEducate Taxpayers; \nProvide a Seamless \nExperience\nConvenient, simple and secure way to access tax \ninformation, make changes to accounts, make \npayments from any device and communicate with the \nIRS that will signifcantly increase the functionality of \nexisting self-service channels\nPersonalized notifcations about changes to tax \nsituation, refund status and reminders, audit status \nand payments through Online Account\nSecure upload and sharing of fles with the IRS\nEnhancements to existing IRS online accounts for \nindividual taxpayers\nNew online accounts for tax professionals and \nbusinesses\nVALUE FOR TAX PROFESSIONALS\nEstablish and maintain authorized relationships with \nclients through the Online Account\nSecure access to clients account information and \nnotices and perform other account services and \nrepresentational duties through their Online Account\nLess time establishing the taxpayer’s authorization to \nact on their behalf\nGOALS\nVALUE FOR THE TAXPAYER\nOBJECTIVES\nInternal Revenue Service \| Taxpayer First Act\nEXPANDED DIGITAL SERVICES\nThe following page outlines the goals, objectives, \ntaxpayer benefts, tax professional benefts, timeline, costs \nand measures associated with Expanded Digital Services.\n", "44\nInternal Revenue Service \| Taxpayer First Act\nSecure Two-Way Messaging\nExpanded Digital Services Timeline and Measures\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n10 years\n• Establish secure one-way \nmessaging through their \nonline account\n• View payment history\n• Integrate refund tracking\n• Provide additional third-party \noptions for making payments\n• Provide the ability to link bank \naccount\n• Opt-in subscription for \nnotifcations \n• Display online payment \nagreement eligibility messaging\n• Display payment agreement \nstatus\n• Provide the ability to create or \nrevise a payment agreement in \nonline account\n• Digital notices w/ opt-in \nsubscription for notifcations\n• Taxpayer Digital \nCommunications Outbound \nNotifcations (TDC-ON) initial \nsolution for certain notices \n• Establish secure two-way \nmessaging through their \nonline account\n• Enhance integrated refund \ntracking\n• Enable the ability to update \naccount information, including \nAddress, Phone Number, etc.)\n• Secure document exchange\n• Deliver ability to view case \nstatus\n• Tax Pro Online Account: \nNotifcations for “Waiting for \nsignature” or “Has been signed” \nstatuses\n• Expanded TDC-ON\n• Expand available types and \nmethods of secure two-way \ncommunications through their \nonline account \n• Issue resolution tracking\n• Increase the functionality of \nonline account \n• Expand secure document \nexchange capabilities \n• Expanded TDC-ON\n• Establish Digital Authorization \n(Form 8821) with eSignature\n• Power of Attorney (Form 2848) \nwith eSignature\n• Add Authorization and POA/\nFully Digital CAF \n• Update/Remove Authorization \nand POA \n• Expedited Access to taxpayer \ntranscripts\n• Notifcations for waiting for \nsignature or has been signed\n• List of Clients with Access to \nOnline Account\n• View payment and notice history\n• View case status\n• Practitioner Premium Access\n• Establish business online \naccount\n• Expanded Tax Pro Account\n• Enhanced digital \ncommunication tools with \nIRS\n• Access to taxpayer online \naccount\n• Expanded notifcations\n• Document exchange\n• Expanded practitioner \npremium access\nTaxpayer View History\nChange Account Information\nDigital Notifcations\nBusiness Online Account\nTax Professional Online Account\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n", "45\nInternal Revenue Service \| Taxpayer First Act\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n10 years\n• Introduce base functionality for \nDigital Signatures\n• Establish Digital Authorization \n(Form 8821) with eSignature\n• Power of Attorney (Form 2848) \nwith eSignature\n• Expand digital signatures to \nmore forms\n• Allow digital signatures for \nthe full universe of forms\nDigital Signatures\n• Establish ability to link bank \naccount\n• Establish third party Access to \nadditional payment vendors\n• Provide additional third-party \noptions for making payments\n• Large and small business \nsecure messaging/fle sharing\n• Expand ability to link bank \naccount\n• Expose APIs to third parties\n• Secure document exchange\n• Expanded Payment Options \nfor all taxpayer segments\n• Tax Professional secure \ndocument exchange\nExpand Payment Options\nSecure Document Exchange\nSTRATEGIC \nGOAL\nOBJECTIVE\nTIER\nWHAT WE ARE \nTRYING TO \nMEASURE\nMEASURE/ INDICATOR\nBASELINE12\nTARGET/\nPROJECTION\nProvide a \nSeamless \nTaxpayer \nExperience\nIncrease Access \nand Promote \nTransparency\nAccess\nProvide taxpayers with \nadditional digital options for \ninteracting with the IRS\nPercent of taxpayer interaction \ntypes that have a digital \nalternative\n39% or 18 interaction \ntypes13\n75% or 35 interaction \ntypes by FY2024\nAdoption\nIncrease use of digital self-\nhelp tools through Online \nAccounts\nNumber of taxpayers with an \nactive secure online profle\n6.51M14\nIncrease by 5% \nannually though \nFY2024\nIncrease use of self-help \ntools\nPercent of taxpayer interactions \naccomplished through self-help \ntools (Enterprise Self Assistance \nParticipation Rate (ESAPR))\n79%15, 16\n82% FY2021 and \nFY2022\nImpact\nTaxpayer burden reduction\nVolume of interactions completed \nthrough self-help options\n(Hours saved)\nVolume: \n581,374,970 FY2019\n503,177\n,386 \nFY201816\nTime savings will \nneed to be designed, \ndeveloped and tested\nTest measures in \nFY2021; Baseline in \nFY2022; Set target/\nprojection for FY2023\nExpanded Digital Services Timeline and Measures\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n12 Baselines are as of the beginning FY2019 unless otherwise noted.\n13 IRS Integrated Modernization Business Plan FY2019 Key Insights Report.\n14 Source: IRS Integrated Modernization Business Plan FY2019 Key Insights Report.\n15 Source: IRS Integrated Modernization Business Plan FY2019 Key Insights Report.\n16 Source: Enterprise Self Assistance Participation Rate.\n", "To augment expanded digital services, we will create a seamless experience that helps \ntaxpayers solve problems and comply with their tax obligations. We will integrate digital tools \nwith other service channels (e.g., toll-free telephone assistance and walk-in assistance) into a \nseamless experience to resolve issues efficiently and further improve the taxpayer experience. \nTaxpayers expect and routinely encounter similar “omni-channel”17 approaches with services like \nonline banking and shopping. Using our omni-channel model, taxpayers will have the fexibility \nto communicate with the IRS and resolve issues via their preferred method and transition \nseamlessly to another resource or channel. The seamless experience will reduce telephone wait \ntimes and help resolve issues more quickly and efficiently. As part of the Seamless Experience, \nwe will equip IRS employees across service and compliance functions to better navigate the \nIRS and to identify resources to solve taxpayer issues outside the scope of their training and \nexpertise.\nThe following key capabilities are the foundation of our Seamless Experience— \n•\nExpand Automated Callback: Allows taxpayers to provide their telephone number and opt for\nan IRS employee to call them back instead of waiting on hold.\n•\nWait Time Transparency: Provides taxpayers estimated wait times to inform their decision on\nwhether to remain on hold, opt for a call back or seek information on IRS.gov.\n•\nConcierge Navigation Support: Gives taxpayer-facing IRS employees the ability to provide\ntaxpayers with the information they need or personally connect them with a subject matter\nexpert who can assist. Each employee will receive calls and handle contacts based on the\nnature of the issue identifed in the web chat, through topic-based routing on the phone or\nduring casework contacts. The employee will resolve all issues within the scope of their training\nand expertise. If the initial employee cannot provide the assistance the taxpayer is looking\nfor, the employee will smoothly transition the taxpayer to a subject matter expert with the\nknowledge and authority to handle the type of taxpayer assistance required.\n•\n360-Degree View of Taxpayer Accounts: Provides IRS employees with a global view of each\ntaxpayer account and gives them access to taxpayer records in real-time, including interaction\nhistory, appointment schedules, etc. This will be available through an ECM system.\n46\nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n4.4 SEAMLESS EXPERIENCE\n17 Omni-channel can be defned as providing a set of seamlessly integrated channels that cater to customer preferences and \nactively steers them toward the most efficient resolution.\n", "• \nArtifcial Intelligence (AI)-Powered Informational Web Chat (Virtual Assistance): \nAllows for an AI-powered chat bot to attempt to answer questions or direct the taxpayer to \nhelpful information on IRS.gov or to their online account based on a taxpayer’s browsing \npreferences on IRS.gov. Chat bots will also be able to connect taxpayers to an IRS assistor \nfor a web chat or voice call. The chatbot will improve over time as the knowledge base \nexpands and more taxpayer experience feedback becomes available. If the chatbot cannot \nresolve a taxpayer’s issue, contact routing will guide the taxpayer to live support from an IRS \nemployee. \n• \nAI-Powered Digital Appointments: Allows taxpayers to speak with an assistor or schedule \nan appointment if the chatbot is unable to resolve a taxpayer’s issue. Taxpayers will also \nbe able to schedule AI-Powered appointments with employees in other IRS organizations, \nlike exam and collection. The chatbot will be able to determine if an assistor is needed and \neither “introduce” the caller to an assistor or schedule an appointment with an employee for \na later time. The appointment could be with a service or compliance employee and can be \nin-person, telephonic, or via secure video chat. \n• \nAI-Powered Employee Assistant: Supports IRS employees when answering taxpayers’ \nquestions with an AI-powered knowledge base that will make suggestions based on a \ntaxpayer’s experience, questions or pages visited on IRS.gov.\nThese capabilities integrate ongoing work within the IRS by creating a stronger, more strategic \napproach to putting taxpayers frst. The IRS is already testing assistor-based chat and AI-\npowered chatbots, and we are improving our callback services. What began as a customer \ncallback solution to support the internally facing service desk has been expanded to include \na taxpayer-facing solution. Both callback deployments have met with considerable success \nwith the service being used more than 700,000 times by taxpayers and 85,000 times by IRS \nemployees. We estimate, in the frst calendar quarter of 2020, taxpayers saved 77\n,000 hours \nper month waiting in queue. Additionally, the IRS recently integrated personalized payment plan \nmessaging into online accounts. \nOnce a taxpayer’s identity has been authenticated, that authentication will carry with them \nthrough the next steps in the process, saving time for both the taxpayer and the IRS. Notably, \nwhen transferring, the assistor will remain engaged with the taxpayer until assured the subject \nmatter expert has picked up the inquiry. Handoffs between employees will be collaborative, and \ninformation will carry forward with the taxpayer. If a subject matter expert is unavailable, the IRS \nassistor will schedule a callback or an appointment, so taxpayers get the help they need. \n47\n4.4 SEAMLESS EXPERIENCE\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n", "48\n4.4 SEAMLESS EXPERIENCE\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n18 See Section 5.0 for additional details on the Training Strategy.\nWe will train employees to answer questions, resolve issues, and identify additional resources \nwithin this omni-channel approach.18 In most instances, IRS assistors will provide initial live \nsupport through web chat with the ability to offer audio or video calls if preferred. As part of our \nTraining Strategy, employees’ skills will increase over time enabling them to resolve more issues \nat the frst point of contact. The strategy will be implemented incrementally over time as funding, \nstaff and technology become available. \nTo facilitate a more seamless experience for the taxpayer, the IRS will modernize the employee \nexperience through Knowledge Bases, an organized source of information to assist employees \nwith taxpayer inquires. In addition, a database of frequently asked questions and automated \ntools will further improve and streamline the employee experience. All employees who have \ncontact with taxpayers will have access to an AI-powered Assistant that will be trained to aid \nthem in meeting the needs of the taxpayer. If the taxpayer issue is complex in nature, the \nemployee - as part of our new concierge navigation model - will be equipped with navigational \nsupport tools and organizational awareness training to identify a subject matter expert who can \nresolve the issue. \nWe recognize that to fully implement the Seamless Experience we must invest in new \ntechnology. For example, the IRS needs an Enterprise Case Management system to give \nemployees a single source for real-time access to a 360-degree view of a taxpayer’s history. \nOur current case management environment is comprised of multiple systems that often cannot \ncommunicate with each other. ECM will allow authorized IRS employees to see a taxpayer’s \nfull account, fling history, relevant case data and prior communications to resolve cases more \nquickly allowing employees to resolve more inquiries in a single contact and better facilitate \nhandoffs. For instance, a revenue agent working with a taxpayer on a compliance issue will be \nable to guide the taxpayer to another function for support on an account issue. \n", "49\nInternal Revenue Service \| Taxpayer First Act\n4.4 SEAMLESS EXPERIENCE\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0\| TAXPAYER EXPERIENCE STRATEGY\nThe IRS receives more than seven million \npieces of paper correspondence per year. \nThere is signifcant opportunity to increase \nefficiencies and improve the taxpayer \nexperience by increasing the ability for \ntaxpayers to submit that correspondence \ndigitally and enabling the IRS to convert \nincoming paper to digital format. The \nIRS vision is to create new and enhance \nexisting digital-frst channels for taxpayers to \ncorrespond with the IRS, alongside enhanced \ndigitalization capabilities to convert residual \npaper into a digital format. This approach will \nmeet taxpayers in their preferred domain, \nwhich is increasingly online and on their \n The current structure confnes \nwork within specifc BODs and limits \ninter-BOD interactions of employees that \nwould more efficiently address problems to \nimprove taxpayer experience.\n—National Treasury Employees Union\nphones. We will still provide paper options for those who may need them as well as enable the \nuse of advanced technologies such as robotics process automation and AI to speed back office \nfunctions, promote self-service and improve the taxpayer experience. Getting paper into digital \nformat will also enhance the employees’ 360-degree view discussed above.\nIn sum, the Seamless Experience is key to our holistic approach to the taxpayer experience \nacross both service and compliance interactions. IRS employees will be empowered and \nequipped with innovative tools to efficiently navigate across IRS operations and access \nKnowledge Bases to deliver seamless experience meeting the needs of taxpayers. This \nenhanced experience will lead to greater transparency, reduced burden and foster voluntary \ncompliance.\n", "50\nInternal Revenue Service \| Taxpayer First Act\nIncrease Access and Promote \nTransparency\nSimplify the Tax Process\nEquip Employees with Tools \nNecessary to Provide Excellent \nTaxpayer Service\nProvide a Seamless \nTaxpayer Experience;\nEmpower, Equip and \nEnable Workforce\nIssues resolved swiftly, easily and conveniently\nInformation from the very frst engagement \nwith the IRS will be transferred seamlessly \nto the next assistor, negating the need for the \ntaxpayer to repeat information\nEfficient and defnitive interactions \nwith the IRS making journey for \nassistance as painless as possible\nA well-trained and better equipped IRS staff able to \nlisten to concerns and be more responsive to any \ntaxpayer issue raised\nLess time waiting on the phone with the expanded \nuse of appointment and call back technology\nGOALS\nVALUE FOR THE TAXPAYER\nOBJECTIVES\nInternal Revenue Service \| Taxpayer First Act \nSEAMLESS EXPERIENCE\nThe following page outlines the goals, objectives, taxpayer benefts, timeline, \ncosts and measures associated with Seamless Experience.\n", "51\nInternal Revenue Service \| Taxpayer First Act\nExpand Automated Callback\nSeamless Experience Timeline and Measures\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n10 years\nWait Time Transparency\n360 Degree View of Taxpayer \nAccounts\nConcierge Navigation Support\nAI-Powered Informational Web Chat \n• Expand telephone customer \ncallback to additional telephone \nlines\n• Deploy expanded toll-free \nportal\n• Introduce callback by \nappointment\n• Increase number of \napplications that offer callback \noptions\n• Add callback to Spanish \napplications\n• Enhance all callback solutions\n• Establish wait time \ncommunication methods\n• Enhance wait time \ncommunication methods\n• Enhance wait time \ncommunication methods\n• Establish robotics and Artifcial \nIntelligence for initial taxpayer \ninterface\n• Test concierge concept on \nlimited basis\n• Rollout training employees on \nthe concierge concept\n• Expand concierge concept \ncapabilities and better equip \nIRS employees to guide \ntaxpayers through the system \n• Increase resolution frequency \nby escalating complex issues \nto a Subject Matter Expert\n• Introduce AI-assisted chat-bot \nfor appointments\n• Introduce AI-assisted employee \nknowledge search\n• Introduce Natural Language \nProcessing by AI\n• Provide “click to contact” for \nLive Assistor Connection from \ndigital interaction\n• Continue to enhance upon \nconcierge routing and processing\n• Design a long-term strategy \nto deliver Enterprise Case \nManagement (ECM) solution \n• Procure ECM Solution\n• Deliver initial case \nmanagement capabilities\n• Enhance ECM solution for \nefficient and seamless view of \nall taxpayer actions, accounts \nand cases\n• Incrementally increase case \nmanagement systems included \nin ECM to build toward a \n360-degree view of Taxpayer \nAccount by IRS Employee\n• Deploy omni-channel model to \n360 degree view of taxpayer \nrecords in real time\n• tax flings\n• interaction history\n• appointment schedule, etc.\n• Deploy AI powered chat-bot \n(virtual assistance) to answer \ntaxpayer questions or direct \ntaxpayers to the information on \nthe IRS.gov\n• Deliver capabilities to \nseamlessly transfer inquiries \nfrom IRS.gov to live IRS \nassistor for a web chat and / or \na voice call \n• Expand AI powered information \nweb chat to include advanced \nvirtual assistance technologies\n• Expand IRS knowledge base \nfor international taxpayers\n• Enhance AI web chat capabilities \nbased on taxpayer feedback and \nevolving industry practices\nInternal Revenue Service \| Taxpayer First Act \n(Virtual Assistance)\n", "52\nInternal Revenue Service \| Taxpayer First Act\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n6-10 years\nAI-Powered Employee Assistant\nAI-powered Digital Appointments\n• Test chat-bot creation of \nappointments\n• Deploy and enhance AI \npowered chat-bot appointments\n• When the issue is not resolved \nduring chatbot interaction, \nchatbot should be able to \n“introduce” the taxpayer to \nan assistor or schedule an \nappointment\n• Enhance chat-bot appointments\n• Establish and test AI-based \nKnowledge Base search for \nIRS assistors\n• Deliver training and Resolution \nGuide to IRS assistors \n• AI natural language support\n• Expand AI knowledge base\n• Improve the clarity of the IRMs \nfocusing on the taxpayer’s \njourney\n• Enhance AI Support and issue \nde-escalation process increasing \nresolution frequency\nSTRATEGIC \nGOAL\nOBJECTIVE\nTIER\nWHAT WE ARE \nTRYING \nTO MEASURE\nMEASURE/INDICATOR\nBASELINE19\nTARGET/\nPROJECTION\nProvide a \nSeamless Taxpayer \n \nExperience\nIncrease Access \nand Promote \nTransparency\nAccess\nAccess to an IRS Assistor \nwhen needed\nEnterprise LOS\n56.63% LOS in \nFY201920 \nTest FY2021; \nbaseline FY2022; \ntarget/ projection \nFY2023\nAdoption\nAccess to an IRS Assistor \nwhen needed\nCalls answered\n25.8M Assistor \ncalls answered in \nFY201921\nDevelop and \ntest measures in \nFY2021; Baseline \nin FY2022, and set \ntarget/projection \nfor FY2023\nImpact\nTaxpayer Satisfaction\nA-11 Survey Question: I am \nsatisfed with the service I \nreceived from the IRS\nDevelop and \ntest measures in \nFY2021; Baseline \nin FY2022, and set \ntarget/projection \nfor FY202322\nDevelop and \ntest measures in \nFY2021; Baseline \nin FY2022, and set \ntarget/projection \nfor FY2023\nSeamless Experience Timeline and Measures\nInternal Revenue Service \| Taxpayer First Act \n19 Baselines are as of the beginning FY19 unless otherwise noted.\n20 2019 Internal Revenue Service: Data Book.\n21 2019 Internal Revenue Service: Data Book.\n22 This question is not currently asked on all telephone lines.\n Currently the enterprise LOS measure does not include all telephone lines, additional lines will be added in FY2021\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n6-10 years\n", "Improving outreach is critical to our Taxpayer Experience Strategy. We want all taxpayers to \nunderstand how to comply with their tax obligations and access our services. With Proactive \nOutreach and Education, the IRS will use various means to reach taxpayers at the right time \nthrough the right format. We will deliver information and personalized messages to taxpayers \nusing social media, simplifed correspondence translated into multiple languages, customized \ndigital options and community outreach through trusted partners. Information may be generated \nbased on issue campaigns, errors the IRS identifes, emerging trends, and other insights \ngathered from our continuous feedback loop. Our success depends, in part, on expanding \ntrusted partnerships with external stakeholders (Community of Partners) as well as amplifying \nefforts to reach underserved communities (Focused Strategies for Underserved Communities), \nwhich we discuss more in the next two Sections of this report. Community outreach, virtual \nseminars, partnerships, and engagements with schools, can assist the IRS in helping taxpayers \nto access services and resolve issues. Ultimately, educating taxpayers will increase taxpayer \nconfdence in our organization, enable them to meet their tax obligations, and enable us to \nbetter anticipate and respond to taxpayer needs. \nThe following capabilities are key to Proactive Outreach and Education— \n• \nPersonalized Tax Updates: Through online accounts, allow taxpayers to opt in to receive \npersonalized notifcations about changes to their tax situation, fling reminders or status \nupdates for refunds, audits, and payments. Further developing online accounts, increasing \ndigital correspondence and providing more electronic reminders and notices will help ensure \ntaxpayers have up-to-date information to comply with their tax obligations.\n• \nSocial Media Strategy: Use multiple social media platforms to share IRS news and \neducational updates that are customized based on demographics and other taxpayer \nbehavioral information. Social media will be used to engage taxpayers, guide them to the \nappropriate channel for service and communicate in a voice and style consistent with the \nrespective platform. As our social media strategy evolves, we plan to incorporate two-way \ncommunication to resolve inquires. \n• \nSimplifed Notices and Correspondence: Analyze and use data to identify necessary \nlanguage translations for our notices and correspondence. Use data to improve the \neffectiveness of our communications in various taxpayer segments. \n53\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n4.5 PROACTIVE OUTREACH AND EDUCATION\nInternal Revenue Service \| Taxpayer First Act \n", "• \nPlain Language Communications: Redesign notices and standardize correspondence \nacross the agency to simplify the format, educate and provide information to taxpayers \nin a manner that is easy to read and eliminate unnecessary legal language. Provide \nclear information and plain instructions to the taxpayers about why they are receiving \nthe communication from us, and what actions they need to take. This may also include \ninstructions for using online accounts for more detailed account information.\n54\n4.5 PROACTIVE OUTREACH AND EDUCATION\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nLEP taxpayers are signiﬁcantly more \nlikely to be aware of IRS information on \nsocial media platforms and to have looked \nfor tax information there compared to \ntaxpayers overall. \n \n— 2017 Taxpayer Experience Survey\n\| WHAT WE HEARD \| \n23 Traditional and Simplifed.\nCurrently, the IRS has an extensive, multi-\npronged communications strategy focused \non print and social media, stakeholder \nrelationships, virtual communications and \nreaching underserved taxpayers. To reach \nLimited English Profciency (LEP) communities, \nthe IRS has developed Twitter, Facebook, and \nYouTube accounts entirely in Spanish and \nadditionally, select posts on Twitter, Facebook, \nLinkedIn and Instagram have been translated \ninto fve additional languages (Vietnamese, \nKorean, Russian, Chinese23 and Haitian \nCreole). Furthermore, there is also a YouTube \nchannel in American Sign Language. We will build on these efforts and use continuous feedback \nand analytics to monitor the effectiveness of our communications and services and to determine \nthe best methods, messengers, and forums to communicate and resolve taxpayer issues early \nand efficiently. The IRS will develop a Social Media Strategy to share content, updates, and \nrespond in a voice and style consistent with the respective platforms and will use technology \nproactively to collaborate with different organizations. \nThrough social media, we can facilitate early issue resolution, including increasing awareness of \nIRS service options and promoting convenient self-service digital tools. The IRS demonstrated \nthis approach with expanded social media work during delivery of the Economic Impact \nPayments. Expanding our social media presence will also allow our external partners, such as \nother government agencies, members of the Congress, and Low-Income Tax Clinics to better \nserve their constituents by easily linking to critical IRS messages. Later in this report, as part of \nour Focused Strategies for Reaching Underserved Communities, we further explain how we will \nuse social media and other outreach practices to communicate with underserved taxpayers and \naddress specifc community needs. \n", "55\n4.5 PROACTIVE OUTREACH AND EDUCATION\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nHistorically, communicating tax information effectively through standardized correspondence \nand notices has presented challenges. With the passage of the Plain Writing Act in 2010, the \nIRS began reviewing and streamlining our correspondence process to restyle and coordinate \nnotices, expedite approvals, simplify language and improve taxpayer responses. We have \nalready taken steps to improve taxpayer correspondence by convening a Correspondence \nSummit and developing a Taxpayer Correspondence Strategy to defne challenges and identify \nopportunities for improvement. Our research suggests that placement of information, color, font, \ntype and spatial design affects the readers’ ability to understand and respond to key information \nin notices and letters. Using evidenced-based approaches, we will design easy-to-understand \ncorrespondence to help taxpayers meet their tax obligations. \nWith Proactive Outreach and Education, the IRS can get the right information to the right \ntaxpayer at the time they need it. \n", "56\nInternal Revenue Service \| Taxpayer First Act\nProvide Clear and \nTimely Communications\nUnderstand Taxpayer Needs\nBuild Trusting Relationships \nand Partnerships\nSimplify the Tax Process \nUnderstand, Inform \nand Educate Taxpayers; \nProvide a Seamless \nExperience \nEfficient and effective communications\nQuicker access to information and \nresolution of issues\nPlain language information and \ncommunications through a variety \nof channels and methods in a variety of \nlanguages\nBetter understanding of tax obligations for \ncommunities and underserved populations\nIncreased availability and accessibility \nfor underserved taxpayers and \ncommunity members\nPersonalized notifcations about changes \nto tax situations to assist them in meeting \ntheir tax obligations and goals\nMore trusting relationship with IRS \nGOALS\nVALUE FOR THE TAXPAYER\nOBJECTIVES\nInternal Revenue Service \| Taxpayer First Act \nPROACTIVE OUTREACH AND \nEDUCATION\nThe following page outlines the goals, objectives, taxpayer benefts, timeline, \ncosts and measures associated with Proactive Outreach and Education.\n", "57\nInternal Revenue Service \| Taxpayer First Act\nProactive Outreach and Education Timeline and Measures\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n10 years\nSocial Media Strategy\nPersonalized Tax Updates\n• Provide taxpayers with \ninformation to open online \naccounts\n• Provide personalized \nnotifcations about changes \nto their tax situation, fling \nreminders or status updates for \nrefunds, audits, and payments\n• Leverage tax data to notify \ntaxpayers about specifc \ncampaigns or upcoming \nchanges impacting them\n• Expand updates to two-way \ncommunication.\n• Deliver information and \neducation through additional \nsocial media platforms based \non topics specifc to taxpayer \ndemographics or businesses\n• Capture data and analytic \npoints for social media \ndemographics information\n• Expand social media platforms \nto attract additional viewers\n• Analyze data to determine \nlanguage translations needed \nfor specifc notices and letters\n• Translate notices and letters \nbased on data analytics for \nspecifc taxpayers for whom \nEnglish is not their primary \nlanguage\n• Use evidenced-based \napproaches to design easy-to-\nunderstand correspondence \nto help taxpayers meet their \ntax obligations e.g. research \nsuggests that placement of \ninformation, color, font, type, \nand spatial design impacts the \nreaders’ ability to understand \nand respond to key information \nin notices and letters\nSimplify and Improve Notices and \nCorrespondence\nPlain Language Communications\nInternal Revenue Service \| Taxpayer First Act\nSTRATEGIC \nGOAL\nOBJECTIVE\nTIER\nWHAT WE ARE TRYING \nTO MEASURE\nMEASURE/\nINDICATOR\nBASELINE24\nTARGET/\nPROJECTION\nUnderstand, \nInform and \nEducate the \nTaxpayer\nProvide Clear \nand Timely \nCommunications\nImpact\nEffectiveness of communications\nConduct 3 - 5 studies to \nassess how improved \nand increased social \nmedia presence impact \ntaxpayer behavior\nDevelop and test \nmeasures in FY2021, \nbaseline in FY2022, \nand set target/ \nprojection for FY2023\nDevelop and test measures \nin FY2021; Baseline in \nFY2022, and set target/\nprojection for FY2023\n24 Baselines are as of the beginning of FY19 unless otherwise noted.\n", "The IRS has many longstanding and successful partnerships with external stakeholders \nincluding tax professional associations, community-based organizations, other government \nagencies, and advisory and industry groups in addition to our cross-functional collaboration \nsupporting bureaus across Treasury. As we build upon existing relationships and seek new \npartners, we are creating a sustainable Community of Partners to explore innovative ways to \nimprove service and lessen taxpayer burden. Expanding our partnerships will help us reach \nunderserved communities, which is discussed further in the next Section of this report. \nOur Community of Partners will focus on the following key capabilities—\n•\nBuilding and Expanding Trusted Stakeholder Network: Use existing partnerships and\ndevelop new ones to improve information-sharing between organizations and collaborate on\nsolving common problems.\n•\nLeveraging Community Outreach Best Practices: Work with our partners to beneft from\ntheir experience in developing community partnerships, such as joining with other agencies\nto learn how they access hard-to-reach communities.\n•\nCo-Locating Federal Government Services: Partner with other federal agencies to allow\nthe IRS to provide co-located services (for example, post offices, U.S. embassies, etc.).\nThese partnerships could apply to both service and compliance interactions.\n•\nExpanding Community Presence: Cultivate trusted relationships with local leaders,\ncommunity centers, cultural and faith communities and organizations and chambers of\ncommerce to help us provide outreach, education and other services. This collaboration will\nalso help us better reach populations that may be underserved or under-represented.\n•\nData Sharing Opportunities: Ensure secure and authorized information-sharing with\nfederal and state agencies, Security Summit25 participants, and other third parties within\nthe boundaries of the established law to allow us to incorporate new sources of information\nfrom a secure network to drive enforcement decisions, combat identify theft and improve the\ntaxpayer experience.\n58\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n4.6 COMMUNITY OF PARTNERS\nInternal Revenue Service \| Taxpayer First Act \n25 Our Security Summit Initiative is a unique partnership between the IRS, state revenue departments and private-sector tax \nindustry leaders. It is the frst public-private partnership of its kind with the goal of putting new and innovative safeguards in \nplace to protect taxpayer information and the integrity of the Federal and state tax systems. \n", "59\n4.6 COMMUNITY OF PARTNERS\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nThe agency must continue \nto build its trusted partner \nnetwork in new and creative \nways, enhancing the \npower of bringing individuals or \n \ngroups to the table to solve a \ncommon problem.\n—IRS Employee\nThis approach to partnerships proved effective during the implementation of recent legislation, \nincluding the Tax Cuts and Jobs Act, Public Law No. 115-97\n. In these instances, the IRS \nfacilitated forums with external groups to obtain valuable input from a cross-section of \nstakeholders. These helpful sessions demonstrated the benefts of institutionalizing the concept \nof a Community of Partners. \nThis past spring and summer, the IRS conducted a \nsweeping outreach and education campaign. In April \n2020, the IRS met with 175 representatives from \n25 government agencies about Economic Impact \nPayments established by the Coronavirus Aid, Relief \nand Economic Security (CARES) Act, Public Law \nNo. 116-136. During this meeting, the IRS discussed \npayment procedures and how to reach specifc \naudiences in need. Stakeholder participants included \nthe Treasury Financial Literacy and Education \nCommission, the Department of Health and Human \nServices, and the Department of Housing and \nUrban Development. The Consumer Financial \nProtection Bureau shared information about scams \nand identity theft. The IRS also shared information \nabout Economic Impact Payments with an additional \n34 federal agencies, 35 state governments, 27 \nlocal governments and with over 200 public service \nagencies, including 324 Indian tribal leaders from around the country. These efforts continued \nthroughout 2020, with IRS outreach efforts expanding, building on a network of thousands of \npartners across the country, inside and outside of the tax community. Agency efforts included \nworking with state and local governments, Congressional offices, as well as many local non-\nproft groups and social service agencies. Many citizens with no tax fling requirement were \neligible to receive an Economic Impact Payment by using the IRS.gov Non-Filers’ tool and we \nengaged our partnership network to assist us with reaching these individuals. For example, \nthe IRS worked with more than 350 local and national organizations to share information about \nEconomic Impact Payments specifcally focused on those experiencing homelessness as well as \nseniors and veterans. These efforts were supplemented with proactive campaigns in traditional \nand social media as well as specially designed toolkits for use by IRS partners. The CARES \nAct passed on March 27\n. Within 14 days taxpayers started seeing Economic Impact Payments \nin their bank accounts. By the end of July, IRS delivered approximately 160 million payments \ntotaling nearly $270 billion. \n", "60\n4.6 COMMUNITY OF PARTNERS\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nFollowing are a few additional examples of this approach:\n•\nCo-location with Social Security Administration (SSA) offices: Since January 2017\n, the\nIRS and the SSA have worked together to jointly provide taxpayers access to information\nand assistance. The co-location of IRS employees in SSA offices began with four SSA\nlocations hosting IRS employees. IRS currently has Taxpayer Assistance Centers (TAC)\nemployees in six SSA offices. IRS employees provide TAC services from SSA sites, including\nface-to-face meetings with taxpayers using the appointment system. The IRS and SSA also\ncollaborate on anti-fraud initiatives. SSA and IRS held multiple meetings in the past year to\ndiscuss anti-fraud best practices. Leaders from both agencies partnered to devise a plan\nto determine the best way to exchange data and best practices. The IRS will continue to\nexpand this service channel as part of our Taxpayer Experience Strategy.\n•\nCommunity outreach best practices with the Department of Education (ED): The IRS\npartnered with the ED White House Initiative on Historically Black Colleges and Universities\n(HBCUs) to expand our Volunteer Income Tax Assistance program on HBCU campuses and\nin some cases, the surrounding communities. Through this program, volunteers prepare\nthousands of tax returns each year.\n•\nExpanded community presence through the Department of Veterans Affairs (VA): The\nIRS has partnered with the VA since 2002 to provide outreach and free tax preparation at VA\ncenters. Our shared goal is to ensure all veterans can easily access our services. The IRS\ncurrently has six sites at VA locations.\n•\nSecurity Summit with States and Private Sector: The Security Summit is an\nunprecedented partnership that includes the IRS, states and the private sector. Between\n2015 and 2019, the number of taxpayers reporting they were victims of identity theft fell\n80%. The IRS protected a combined $26 billion in fraudulent refunds by stopping confrmed\nidentity theft returns. As we got better at blocking returns from entering our systems, the\nnumber of confrmed identity theft returns declined to the point where in 2019 it was 68%\nbelow 2015.\nThese amplifed efforts will bring together partners from across the tax community and the \nFederal Government to improve access to our services, reach diverse communities and drive \ninnovative ways to improve the taxpayer experience. \n", "61\nInternal Revenue Service \| Taxpayer First Act\nBuild Trusting Relationships and \nPartnerships\nProvide Clear and \n5imely $ommunicationT \nSimplify the Tax Process \nUnderstand Taxpayer Needs\nUnderstand, Inform \nand Educate \nTaxpayers; \nProvide a Seamless \nTaxpayer Experience\nImproved relationship between agency, \npartners, stakeholders and taxpayers\nEnhanced and improved fling experience\nExpanded access to information\nIncreased ability to voluntarily comply \nwith tax laws\nIncreased ability to fle complete and \naccurate return\nExpanded service channels and partners\nCustomized interaction assistance \nDecreased taxpayer burden\nGOALS\nVALUE FOR THE TAXPAYER\nOBJECTIVES\nInternal Revenue Service \| Taxpayer First Act\nCOMMUNITY OF PARTNERS\nThe following page outlines the goals, objectives, taxpayer benefts, timeline, \ncosts and measures associated with Community of Partners.\n", "62\nInternal Revenue Service \| Taxpayer First Act\nCommunity of Partners Timeline and Measures\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n10 years\nBuild and Expanding Trusted \nStakeholder Network\n• Begin network design\n• Establish agency/stakeholder \nrelationships\n• Develop/implement \nstrategic plan\n• Baseline critical taxpayer needs \nin relevant taxpayer groups and \nunderserved communities\n• Design outreach programs and \nalign key partners/stakeholders \nto assist relevant taxpayer \ngroups and underserved \ncommunities\n• Implement outreach programs \nand events in key taxpayer \ngroups and underserved \ncommunities\n• Begin annual reassessment of \nservices provided in relation to \nneeds in key taxpayer groups \nand underserved communities\n• Continue building and- \nredefning programs to better \nserve key taxpayer groups and \nunderserved communities\n• Establish agency/partner \nworking groups to create co-\nlocation parameters and ideals\n• Implementation of service \nofferings in co-located \ngovernment services\n• Continue expansion of co-\nlocated services\n• Establish agency/partner \nworking groups to reach \npreviously underserved \ntaxpayers\n• Implementation of programs \nand services in underserved \ntaxpayer populations\n• Expand data sharing \nopportunities with other state/ \nfederal agencies, and other \nthird parties\n• Establish strong Community \nof Partners with state/federal \nagencies, and other third \nparties where data sharing is \ngoverned and formalized\n•\nContinue building and \nexpanding efforts across \nadditional underserved taxpayer \npopulations\n•\nContinue expansion work with \nother federal/state agencies, \nand third parties to build \nApplication Programming \nInterfaces (APIs) where possible\nLeverage Community Outreach \nBest Practices\nCo-Located Government Services\nExpand Community Presence\nData Sharing Opportunities\nInternal Revenue Service \| Taxpayer First Act\nSTRATEGIC \nGOAL\nOBJECTIVE\nTIER\nWHAT WE ARE \nTRYING TO \nMEASURE\nMEASURE/\nINDICATOR\nBASELINE26\nTARGET/\nPROJECTION\nUnderstand, Inform \nand Educate\nBuild \nTrusting \nRelationships\nAccess\nTotal number of new agency \ncollaborations with \npartners and stakeholders\nNumber of new \npartnership forums \nconducted each year\nDevelop and test \nmeasure in FY2021, \nbaseline in FY2022, \nand set target/ \nprojection \nfor FY2023\nDevelop and test \nmeasure in FY2021, \nbaseline in FY2022, \nand set target/ \nprojection for FY2023\nAdoption\nLevel of participation in \npartnership forums\nParticipation in \npartnership forums \nDevelop and test \nmeasure in FY2021, \nbaseline in FY2022, \nand set target/ \nprojection \nfor FY2023\nDevelop and test \nmeasure in FY2021, \nbaseline in FY2022, \nand set target/ \nprojection for FY2023\nImpact\nIncrease in taxpayer satisfaction \nwith IRS\nLevel of satisfaction with \nservice received \nthrough partnerships\nDevelop and \ntest measure in \nFY2021, baseline \nin FY2022, and set \ntarget/ projection for \nFY2023\nDevelop and test \nmeasure in FY2021, \nbaseline in FY2022, \nand set target/ \nprojection for FY2023\n26 Our Baselines are as of the beginning of the FY2019 unless otherwise noted.\n", "63\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n4.7 FOCUSED STRATEGIES FOR REACHING \n UNDERSERVED COMMUNITIES\nInternal Revenue Service \| Taxpayer First Act \nFor those with English \nas a frst language the IRS \nwebsites and general information \nis difficult to understand, therefore \nfor those without English as a frst \nlanguage it can be impossible to \ncomprehend. More resources in \nmore languages is a must.\n—American Citizens Abroad\nOur focused program for underserved communities will unify existing IRS efforts and involve our \nCommunity of Partners to further address issues of communication, education, transparency, \ntrust, and limited access to high-quality products and services, including lack of access to digital \nresources. We need a focused approach as some segments of the taxpayer population face \nunique challenges in getting access to the information and services needed to comply with their \ntax obligations. These traditionally underserved communities are not limited to, but include:\n•\nTaxpayers with limited English profciency\n•\nNative American communities\n•\nMembers of the armed forces\n•\nTaxpayers with disabilities, including\ntaxpaying populations needing special\nassistance due to sight, hearing, dexterity,\nlimited mobility, and cognitive challenges\n•\nElderly taxpayers\n•\nLow-income taxpayers\n•\nTaxpayers living in rural communities\n•\nInternational taxpayers\nIn addition to the IRS’s existing initiatives, \nwe will develop an agency-wide strategy for \nunderserved communities to enhance existing \nprograms, products and services. Working with \nour partners such as the Taxpayer Advocate \nService, Low Income Tax Clinics, Taxpayer Advocacy Panel, Equity, Diversity and Inclusion, \nand Customer Assistance, Relationships and Education, we will learn more about the unique \nneeds of these segments. We will identify best practices to customize our approach to meet the \nspecifc needs of each underserved segment and provide personalized education and outreach \nthrough the service channels and in the languages preferred by these taxpayers. Additionally, we \nwill design our underserved strategies to help us identify and develop accessible products and \nservices. We can use our Community of Partners and co-located services to amplify our efforts. \nThrough these efforts, we will build trust and confdence in the IRS among underserved \npopulations, increase our emphasis on fairness, expand access to information and services \nand increase voluntary compliance. Creating a single, agency-wide program will ensure the IRS \nmeets underserved communities where they are and that IRS messages reach intended\n", "recipients in the languages they need. Additionally, expanding existing partnerships will allow us \nto efficiently identify best practices, while benefting from economies of scale.\nTo illustrate our approach, we outline key aspects of our strategies for two specifc underserved \ncommunities below. \nMultilingual Strategy\nMore than 20% of U.S. residents speak a language other than English at home. Of these \napproximately 66.6 million people, 26 million describe themselves as speaking English “less \nthan very well” and are considered individuals with limited English profciency.27 \nThe key capabilities for our Multilingual Strategy are— \n• \nTranslate Forms, Publications and Notices: Increase the languages available for most \nwidely used forms, publications and notices. \n• \nDigitally Aided Translation and Interpretation: Translate documents and phone \nconversations to other languages.\n• \nRecruitment: Increase incentives for prospective bilingual / multilingual employee and \nspecify the languages we are looking for during hiring.\n• \nLeverage Employee Multi-lingual Skills: Incentivize employees to be certifed as multi-\nlingual and recruit these employees to provide multi-lingual assistance and services. \n• \nTranslation App: Enable better communication between feld employees and taxpayers in \ntheir preferred language using a new translation application for mobile devices.\n64\n4.7 FOCUSED STRATEGIES FOR REACHING \n UNDERSERVED COMMUNITIES\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n This strategy will \nguide the direction, mission \nalignment, investments, and \naccountability of the IRS community \nin providing meaningful access \nfor multilingual taxpayers to IRS \nproducts and services. \n—Charles Rettig, Commissioner\n“ \n27 2018 American Community Survey, Census Bureau. \nEarlier this year, the IRS began rolling out a new \nagency-wide Multilingual Improvement Strategy. As \npart of this effort, we charged our Language Services \nExecutive Advisory Committee with expanding \navailable platforms and increasing available \nlanguages across multiple channels, including \ndigital tools, telephone assistance, tax forms and \npublications, written correspondence and outreach \nand education. While the strategy will continue to \nevolve and improve, most of these capabilities will be \ndelivered by the end of FY2022. In addition, the IRS \nexpanded outreach efforts to these groups as part \nof the Economic Impact Payment public awareness \ncampaign. More than 250 new partnerships were \ncreated with non-traditional tax groups, including \ndozens in the LEP community.\n", "• \n \n65\n4.7 FOCUSED STRATEGIES FOR REACHING \n UNDERSERVED COMMUNITIES\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n28 Wage and Investment, Research and Analysis Division Research Study Report: Understanding the International Taxpayer \nExperience: Service Awareness, Use, Preferences and Filing Behaviors, February 2010.\nInternational Strategy \nNon-resident individuals and businesses with a connection to the United States have unique \ntax considerations and may have difficulty accessing IRS services. They tend to rely on IRS.gov \nas their main resource for information on U.S. fling requirements, taxable income, tax treaties, \npayments, etc. Yet, because they often lack U.S. fnancial accounts or have foreign addresses \nand international telephone numbers, these taxpayers are frequently unable to access online \nIRS services due to current identity proofng and authentication standards. Also, as of tax year \n2017\n, only 48.4% of international individual taxpayers fled electronically,28 compared to 88.3% \nof domestic individual taxpayers. As a result, there is a tremendous opportunity to increase \ninternational taxpayer use of the IRS eFile program. \nAdditionally, a key part of the International Strategy is improving communications to \naccommodate language preferences and challenges. IRS systems will be improved to allow \nfor taxpayers to indicate their primary language and expand service channels to provide virtual \noptions.\nThe key attributes of our International Strategy are— \n• \nInternational Online Account Authentication: Expand online account authentication to \ninternational taxpayers to provide access to additional self-service channels including the \nexpanded digital tools and seamless experience described above. \n• \nFocused Promotion of IRS eFile: Continue promoting IRS eFile to increase electronic fling, \nexpedite the fling process and reduce errors, ultimately improving the taxpayer experience \nfor international taxpayers.\n• \nVirtual Face-to-Face: Provide the ability for taxpayers to have a scheduled video chat with \nan IRS employee, using computer, tablet or mobile phone. \n• \nVirtual Discussion Forums: Facilitate a new virtual discussion forum where taxpayers \ncan initiate discussions around fling requirements, rules, procedures, and other topics. \nThe forums will provide a moderated outlet for asking questions and sharing answers. \nInternational taxpayers will also have the ability to be a part of virtual one-on-one or group \nconference via the forums. \nOur Multilingual and International Strategies are two examples of a broader IRS effort to \nintegrate and coordinate activities focused on underserved communities. Working with these \npartners and conducting additional research will help us better understand the unique needs \nof these segments. With these strategies, we hope to transform underserved communities into \nwell-served communities.\n", "66\nInternal Revenue Service \| Taxpayer First Act\nProvide Clear and Timely \nCommunications\nUnderstand Taxpayer Needs\nBuild Trusting Relationships and \nPartnerships \nIncrease Access and Promote \nTransparency\nUnderstand, Inform and \nEducate Taxpayers; \nProvide a Seamless \nTaxpayer Experience\nTailored outreach, education, \ncommunications, products and services\nUnderstanding of tax obligations and easier \naccess to the tools that lead to compliance\nCommunication in preferred language \nthrough preferred communication channels\nAwareness of the different ways to engage \nthe IRS for assistance when necessary\nGreater trust in the Federal Government\nIncreased emphasis on the fairness of \nthe tax system\nGOALS\nVALUE FOR THE TAXPAYER\nOBJECTIVES\nInternal Revenue Service \| Taxpayer First Act \nFOCUSED STRATEGIES FOR REACHING \nUNDERSERVED COMMUNITIES\nThe following page outlines the goals, objectives, taxpayer benefts, timeline, \ncosts and measures associated with Focused Strategies for Reaching \nUnderserved Communities\n", "67\nInternal Revenue Service \| Taxpayer First Act\nFocused Strategies for Reaching Underserved Communities \nTimeline and Measures\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n10 years\n• Translate 1040 and associated \nforms in 5 additional languages \n(Spanish, Chinese Traditional/\nSimplifed, Korean, Russian, \nVietnamese) \n• Translate Pub 17 in 5 additional \nlanguages\n• Send translated notices \nsystemically\n• Continue to analyze the most \nhighly used forms, publications \nand notices to identify potential \ncandidates for translation into \ntop fve languages \n• In 2020, IRS implemented \nlanguage preference indicator \nas a part of the form 1040 \npackage. We will use data \ngathered through this \nprioritization of translation \nbeginning in 2023\n• Continue to analyze the most \nhighly used forms, publications \nand notices to identify potential \ncandidates for translation into top \nlanguages\n• Translation software \nassessment (translates text)\n• Translation software pilot \n(translates text)\n• Launch digitally translated voice \nconversation software\n• Establish multilingual hiring \nneeds\n• Continued multilingual recruiting \n• Expand existing process and \nincentives for employees to \nbecome certifed as multilingual\n• Launch new multilingual \ncertifcation program\n• Promote new multilingual \ncertifcation program \n•\nPilot digitally translated \nvoice conversation software\n•\nRelease translation software \n(text) for IRS employee use \nservice-wide \n•\nUpdate recruitNFOU \nchannels and incentives\n•\nExecute multilingual \nrecruitNFOU plan\n•\nContinued promotion of \nmultilingual efforts\n• Continued promotion of \nmultilingual efforts\n• Assess translation mobile apps \ncompatible on government \nissued mobile devices\n• Pilot translation mobile app\n• Launch app in IRS suite of \napps for government issued \nmobile devices\n• Assess identity proofng \noptions to allow authentication \nof individual taxpayers living \nabroad\n• Pilot online account \nauthentication of individual \ntaxpayers living abroad\n• Implement online account \nauthentication for individual \ntaxpayers living abroad\n• Identify the best ways to \npromote IRS eFile to individual \ntaxpayers living abroad \n• Promote IRS eFile to individual \ntaxpayers living abroad \n• Continued promotion of IRS \neFile to individual taxpayers \nliving abroad\n• Continued promotion of IRS\neFile to individual taxpayers \nliving abroad\nTranslate Forms, \nPublications and Notices\nDigitally Aided Translation and \nInterpretation\nRecruitment\nLeverage Employee Multilingual \nSkills\nTranslation App\nInternational Online Account \nAuthentication\nFocused Promotion of \nIRS Free File\nInternal Revenue Service \| Taxpayer First Act\n", "68\nInternal Revenue Service \| Taxpayer First Act\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n6-10 years\n• Expand virtual face-to-face \ntechnology as alternative to \nmore face-to-face service \nchannels \n• Expand virtual face-to-face \ntechnology as alternative to \nmore face-to-face service \nchannels\n• Expand virtual face-to-face \ntechnology as alternative to all \nface-to-face service channels\n• Assess products to host online \nvirtual discussion forum\n• Develop policies and \nprocedures for IRS to provide \nresponses\n• Pilot virtual discussion forum\n• Implement virtual discussion \nforum\nVirtual Face-to Face\nVirtual Discussion Forums\nSTRATEGIC \nGOAL\nOBJECTIVE\nTIER\nWHAT WE ARE \nTRYING TO \nMEASURE\nMEASURE/\nINDICATOR\nBASELINE29\nTARGET/\nPROJECTION\nUnderstand, Inform \nand Educate the \nTaxpayer; \nProvide a Seamless \nTaxpayer Experience\nUnderstand \nTaxpayer Needs;\n Increase Access \nand Promote \nTransparency\nAccess\nIncrease the initiatives \ndeveloped as a result of \nunderserved strategies\nNumber of products and \nservices implemented \nas a result of an \nunderserved strategy\nDevelop and \ntest measure in \nFY2021, baseline \nin FY2022, and set \ntarget/ projection for \nFY2023\nDevelop and \ntest measure in \nFY2021, baseline \nin FY2022, and set \ntarget/ projection for \nFY2023\nAdoption\nIncrease the adoption of new \ninitiatives developed as a result \nof an underserved strategy\nNumber of taxpayers by \nunderserved community \nthat use new product or \nservice\nDevelop and \ntest measure in \nFY2021, baseline \nin FY2022, and set \ntarget/projection for \nFY2023\nDevelop and \ntest measure in \nFY2021, baseline \nin FY2022, and set \ntarget/ projection for \nFY2023\nImpact\nIncrease the taxpayer \nsatisfaction with new products \nor services which are \ndeveloped as a result of an \nunderserved strategy\nTaxpayer Feedback via \nSurvey Question via \nForesee and/or ECSS\n“I am satisfed with \nthe product/service I \nreceived from IRS.”\nDevelop and \ntest measure in \nFY2021, baseline \nin FY2022, and set \ntarget/ projection for \nFY2023\nDevelop and \ntest measure in \nFY2021, baseline \nin FY2022, and set \ntarget/ projection for \nFY2023\nFocused Strategies for Reaching Underserved Communities \nTimeline and Measures\nInternal Revenue Service \| Taxpayer First Act \n29 Baselines are as of the beginning of FY2019 unless otherwise noted.\n", "We can make better use of data, a core business asset, to drive compliance decisions and \nimprove the taxpayer experience in all the ways described throughout this strategy. To get \nthere, the IRS needs a data management strategy that uses agency-wide operating data; other \nfederal, state, and publicly available data; secure information sharing with IRS partners; and an \nunderstanding of taxpayers’ experiences, emerging needs and expectations. Taxpayer account \nand service usage data will inform how to improve existing services and develop new digital \ntools. Similarly, analytics will drive better enforcement issue identifcation and case selection.\nThe following key capabilities will allow the IRS to manage data efficiently for taxpayer service \nand enforcement— \n• \nAutomated Feedback Loop: Provide a better taxpayer experience, based on feedback \ncollected from taxpayers, IRS employees, survey data or from automated tools and reports. \nBuild on our ability to use information and feedback by providing real-time access for quick \nanalysis to improve services for taxpayers.\n• \nCapturing a Comprehensive Set of Data Assets: Advance data access, usability, and \ngovernance to inform decision making and improve operational outcomes across the \nenterprise. To make this happen, the IRS will iteratively expand its data environment, \nto include making data more readily accessible through transition from paper to digital \nenvironment, allowing analysts to solve data-driven problems faster. This comprehensive \ndata repository will be built on fundamental data collection principles of gathering, defning, \nperfecting, and storing information. This will inform better compliance enforcement decisions, \nwhich will in turn reduce the burden on compliant taxpayers and direct IRS enforcement \nresources more strategically. \n• \nEmploying Advanced Data Analytics: Analyze behavioral research and other data to better \nidentify and separate taxpayers who are trying to comply from those who are intentionally \nviolating our tax laws, minimizing compliance contacts where direct enforcement activity \nwould not be necessary. This will also help us avoid placing compliant taxpayers into \ncompliance treatments while enhancing detection of non-compliant taxpayers so we can \nrespond appropriately to encourage compliant behavior.\n69\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\n4.8 ENTERPRISE DATA MANAGEMENT AND \n ADVANCED DATA ANALYTICS\nInternal Revenue Service \| Taxpayer First Act \n", "70\n4.8 ENTERPRISE DATA MANAGEMENT AND \n ADVANCED DATA ANALYTICS\n4.0 \| TAXPAYER EXPERIENCE STRATEGY\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n• \nData Sharing Opportunities: Implement secure and authorized information sharing with \nfederal and state agencies, Security Summit participants, and other third parties, within the \nboundaries established by law - by creating new software applications using Application \nProgramming Interfaces where feasible. This will allow us to incorporate new sources of \ninformation to drive enforcement decisions, combat identity theft and improve the taxpayer \nexperience. Adherence to 26 U.S.C. Section 6103 is critical to ensure taxpayer return data is \nadequately protected.\nImplementing enterprise data management will bring many benefts. A robust collection of IRS \ntaxpayer data sources, including customer account, customer service, and third-party data \nwill help the IRS better identify underserved communities, design focused digital tools and \nstrategies, and offer opportunities for the IRS to launch proactive alerts, resulting in avoidance of \nunintended tax issues. For example, feedback loops will be signifcantly improved with the ability \nto monitor information agency-wide. Expanded feedback loops may also help identify areas for \nproactive outreach and education and opportunities to partner with federal and state agencies \nto address non-compliance. Strong security protocols and continuous monitoring of programs \nwill protect taxpayer information from unauthorized access and safeguard IRS systems against \ncyberattacks. \nThe IRS has already started this effort, and our strategy will be based on that foundation. \nBuilding this data management system will take time and signifcant fnancial investment. In \norder to beneft from this vast set of data and information, the IRS needs to strengthen its ability \nto collect and integrate large, diverse datasets from which decisions and discoveries are based, \nensure we are capturing and utilizing the most complete and accurate taxpayer information, and \nexpanding governing relationships through better sharing of data assets. Through an appropriate \ngovernance process, the IRS will take a prudent and disciplined approach to identifying and \nsequencing the most essential data assets to be added to the data repository. The IRS will \nbe able to use comprehensive data to improve existing analytic methods, expand analytical \ncollaboration, and drive greater digital enhancements for tax administration.\n", "71\nInternal Revenue Service \| Taxpayer First Act\nExpanded access to services, both assisted \nand self-digital\nBetter use of artifcial intelligence and data \nanalytics, delivering greater accuracy in \nidentifying potential compliance risks\nIncreased quality of interactions, both assisted \nand self-digital\nQuicker resolution and more transparent \ncustomer service for taxpayers\nLaunch of customized proactive alerts resulting \nin avoidance of unintended tax issues\nImproved taxpayer service based on real-\ntime evaluation of information via feedback \nloop from taxpayers, IRS employees and \nautomated tools\nGOALS\nUnderstand, Inform and \nEducate Taxpayers; Provide \na Seamless Taxpayer \nExperience; Equip, Enable \nand Empower the Workforce\nOBJECTIVES\nProvide Clear and Timely CommunicationT \nUnderstand Taxpayer Needs\nIncrease Access and Promote Transparency \nSimplify the Tax Process\nEquip Employees with the Tools Necessary \nto Provide Excellent Taxpayer Service\nIncrease Employee Knowledge \nand Expertise\nEmpower Employees to Solve \nTaxpayer Issues\nVALUE FOR THE TAXPAYER\nInternal Revenue Service \| Taxpayer First Act\nENTERPRISE DATA MANAGEMENT AND \nADVANCED ANALYTICS\nThe following page outlines the goals, objectives, \ntaxpayer benefts, timeline, costs and measures associated \nwith Enterprise Data Management and Advanced Analytics\n", "72\nInternal Revenue Service \| Taxpayer First Act\nAutomated Feedback Loop\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n10 years\n• Incorporate feedback, in real \ntime\n• Employ advanced data analytic \nstrategies for service delivery \nand compliance purposes\n• Increase efficiency gains on \nwork processes where robotic \nprocess automation is applied\n• Build on analytics efforts \nunderway with the IRS \nresearch community\n• Expand data sharing \nopportunities with other state, \nfederal agencies, and other \nthird parties\n• Capture a more \ncomprehensive set of data \nassets for operational, \nservice, and analytic \npurposes\n• Expand feedback loop concept \nfor numerous IRS operations \nand processes\n• Establish data points from \ntaxpayers, employees, and \nautomated systems for \nfeedback loop\n• Increase availability of \ntaxpayer data for \ndownstream business \nprocesses in a \nmachine-readable format\n• Increase number of IRS \nbusiness processes using \nArtifcial Intelligence (AI), \nNatural Language Processing \n(NPL), Process Automation \n(Robotics), and Machine \nLearning\nCapturing a Comprehensive \nSet of Data Repository\nEmploying Advanced Data \nAnalytics\nData Sharing Opportunities\n• Establish strong Community \nof Partners with state, federal \nagencies, and other third \nparties where data sharing is \ngoverned and formalized\n• Expand working with other \nfederal agencies, state \nauthorities, and third parties to \nbuild Application Programming \nInterfaces (APIs), where \npossible\nEnterprise Data Management and Advanced Analytics \nTimeline and Measures\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nSTRATEGIC \nGOAL\nOBJECTIVE\nTIER\nWHAT WE ARE\n TRYING TO\n MEASURE\nMEASURE/\nINDICATOR\nBASELINE30\nTARGET/ \nPROJECTION\nEquip, Enable and \nEmpower \nWorkforce\nEmpower \nEmployees to \nSolve Taxpayer \nIssues\nAccess\nIncrease percent of captured \nelectronic, paper, and other data \nassets for anomaly detection, \ncase selection, and other \ncustomer service initiatives \nCaptured data \nelements in central \ndata repository\n245,000 data elements31\nIncrease percentage \nof data elements \nwithin centralized data \nrepository by 5% by \nFY2023\nIncrease availability of taxpayer \ndata for downstream business \nprocesses in a machine-\nreadable format\nData tables available \nwithin the data \nrepository for \nbusiness analytics\n3,000 data tables32\nIncrease percentage of \ndata tables within the \ndata repository by 10% \nby FY2023\nImpact\nPercent of individual taxpayers \nwith repeat non-compliance two \nyears after the initial tax year \nfor fling, payment, or reporting \ncompliance\nRepeat Non-\nCompliance Rate\n29.2% \n(FY2017)33\nIndicator - anticipate \nreporting as “Indicator” \nin the FY2022 CJ\n30 Baselines are as of the beginning FY2019 unless otherwise noted.\n31 Source: Compliance Data Warehouse.\n32 Source: Compliance Data Warehouse.\n33 Source: Compliance Data Warehouse.\n", "73\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\nS E C T I O N5\nInternal Revenue Service \| Taxpayer First Act \nTRAINING\nSTRATEGY\nInternal Revenue Service \| Taxpayer First Act \n", "74\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\nOur employees are the primary way we instill confdence in taxpayers and increase trust in \ntax administration. IRS employees must be well trained, adept, and knowledgeable to provide \nexceptional taxpayer service. To implement our Taxpayer Experience Strategy and improve \ntraining across the IRS, we will strive to create a centralized educational organization, or “IRS \nUniversity,” to support the IRS mission. This will allow for a strategic curriculum that will instill the \nimportance of taxpayer service in all employees. High-quality, taxpayer-frst training will further \ndevelop employee skill sets, improve morale, increase productivity, enhance knowledge transfer \nbetween employees, and foster innovation. \nBased on clear goals and long-term strategic plans, we will align our training with the Taxpayer \nExperience Strategy and Organizational Redesign Strategy to provide IRS employees with \ndeveloped curricula, “just-in-time” courses, continuous learning, and professional development. \nOur Training Strategy will enhance previous efforts and our Service-wide approach will enable \ntraining to be more relevant and holistic for employees. Updating and integrating innovative \ntechnological tools will further ensure employees across the IRS receive consistent, high-quality \ntraining. A continued commitment from leadership is critical to meeting employees’ training and \ndevelopment needs now, and in the future. \nWe developed this strategy after months of outreach and extensive research. As part of this \neffort, we visited IRS locations around the country to observe work processes and interview \nemployees at all levels of the organization. Additional focused interviews gave us insight into \nthe current training environment and helped us to pinpoint where key stakeholders (including \npartners and parties both internal and external to the IRS) think improvements are needed. We \nalso assessed best practices across government and the private sector to identify ways to better \nmeet the needs of our high-performing workforce. \nEmployees emphasized the importance of investing in development throughout their careers. \nTraining should be timely and interactive and should use multiple delivery methods to ensure \na high quality and engaging training experience. Stakeholder feedback revealed that we need \nto better use internal resources to eliminate knowledge gaps and centrally manage vendor \ncontracts for improved economies of scale. Stakeholders also stressed the importance of \n5.1 INTRODUCTION AND \n EXPLANATION OF \n STRATEGY\n7\n4\nInternal Revenue Service \| Taxpayer First Act \n", "75\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\nusing integrated technology and data to drive decision-making about training needs. The IRS \nmust also provide adequate IT infrastructure to support a variety of online and virtual learning \nopportunities in addition to supporting our core business of tax administration.\nTraining Strategy Key Components\nWith a university model as the centerpiece of our new approach, our Training Strategy has \nseveral critical components: \n \nIRS University (IRSU) to establish an innovative, centralized learning function within the \nIRS that relies on technology to provide enhanced training experiences for employees. \nIRSU will begin by establishing four academies including Taxpayer Service, Tax \nAdministration, IT and Operations Management and Leadership to organize all training \ncurricula and developmental activities that align under IRS functions discussed in Section \n6. The four-academy structure will meet the needs of IRS as it transitions to a more \ntaxpayer centric approach and structure and also supports continuous employee learning \nand development around structured yet fexible career paths. \n \nTaxpayer-First Training to equip all IRS employees with a working knowledge of our \nTaxpayer Experience Strategy, Taxpayer Rights, and organizational awareness through \na standardized curriculum, while encouraging professionalism, effective communication \nand empathy. The IRS will also emphasize training on civility, inclusive behaviors, cultural \ncompetency, taxpayer rights, understanding taxpayer needs, and multi-language access. \nContinuous Learning For All Employees to establish and promote a continuous \nlearning environment. This will equip employees to perform their current role, develop \nhigher levels of technical expertise along a career path, and support the acquisition \nof portable skills (such as project management, effective communication and risk \nmanagement) that allow individuals to change roles within the IRS. Since the last \nsubstantial reorganization the IRS has undergone a variety of changes in how it conducts \nits business. As technology advances so must the IRS workforce. Continuous learning \nallows us to reskill employees based on changing organizational needs as we implement \nthe key components of the taxpayer experience strategy and adjust the organizational \nstructure to better serve the public. Our approach includes the use of competency \nassessments, career pathing and career planning tools that provide employees \nopportunities to re-skill and upskill.\n5.1 INTRODUCTION AND EXPLANATION \n OF STRATEGY\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n", "76\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n \nUtilizing Technology to improve technology to create accessible, high-quality and \neffective training programs to optimize the employee training experience. We will \nimplement new technology to accommodate the administration, delivery and tracking of \nthe training lifecycle. \n \nMeasuring Success to evaluate feedback on training from employees, taxpayers and \nkey stakeholders. The IRS will use this feedback to make necessary training adjustments \nand continuously improve our training capabilities.34 \n76\n5.1 INTRODUCTION AND EXPLANATION \n OF STRATEGY\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n5.0 \| TRAINING STRATEGY\n34 U.S Office of Personnel Management Training Evaluation Field Guide Demonstrating the Value of Training at Every Level \nJanuary 2011\n.\n Training is one of the most important \nprograms that needs addressing. If the \nQuality and Empathy is there – it will go \nbeyond making the IRS a great place to \nwork. It will give the employees a source \nof pride.\n—IRS Employee\nOur Training Strategy is closely aligned \nwith the Taxpayer Experience Strategy \nand the Organizational Redesign \nStrategy. Improved fundamental \ntraining will ensure that all employees, \nregardless of their roles within the IRS, \nhave a positive effect on the taxpayer \nexperience. We will integrate new \ntaxpayer-service concepts into current \ntraining to ensure employees are well \nequipped to solve taxpayer issues. A \nmore unifed approach to employee \ndevelopment will make us more fexible \nand responsive to the ever-changing \nneeds and priorities of taxpayers and our partners. Successfully implementing this agency-wide \nstrategy will require leadership commitment and a strategic governance structure to ensure \naccountability and effectiveness.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n77\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n77\nInternal Revenue Service \| Taxpayer First Act \n5.2 IRS UNIVERSITY\nWe want \neveryone at the \nIRS to advance and \ndo well at their job.\n—Senior Executive IRS Employee\nIRS will strive to establish an innovative, centralized \nlearning organization that relies on technology to \nprovide enhanced training experiences for employees \nsimilar to Corporate Universities models that are used \nsuccessfully across government and in prominent \nprivate sector organizations. A newly-created IRSU \nwithin IRS would seek to serve as the umbrella for \ndeveloping and educating employees to deliver the \nIRS mission and our strategic plan by strengthening \nindividual and organizational learning, knowledge, \ncompetencies and skills. In this university model, \nexperts in learning and education delivery, policies and \nguidelines will support the development and execution \nof training activities and content to ensure a consistent, high-quality experience. IRSU will \ninitially establish four academies, Taxpayer Service; Tax Administration; IT and Operations \nManagement; and Leadership Development, that will serve to unify and organize training and \ndevelopment activities across the agency. IRSU will partner closely with operating divisions to \nprovide subject matter experts from across the IRS to develop and deliver training activities and \ncontent. Coordination across the IRS will support the development of relevant and high-quality \ncontent, skilled instructors, strong delivery platforms whether in person or virtual. Continued \ncommitment from leadership will enable employees to develop along career paths. IRSU will \nidentify the offerings in these areas that best meet IRS organizational and employee needs. We \nwill establish these key areas with an emphasis on equity, diversity, and inclusion. This model \nwill provide numerous benefts to the IRS, including consistent training across organizations; \nimproved alignment between learning, development, and the IRS Strategic Plan; and reduced \nresource duplication between operating divisions. \nThe IRS University will feature— \n• \nRequirements Planning: We will use organizational workforce planning data and skills \nassessment tools to create an agency-wide, standardized needs assessment process. We \nwill develop this needs assessment process to continuously identify skill gaps based on \ninput from key stakeholders to ensure employees’ training needs are met. This approach \nwill help us identify opportunities to enhance the taxpayer experience through training and \ndevelopmental activities.\n", "78\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n78\n5.2 IRS UNIVERSITY\n5.0 \| TRAINING STRATEGY\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n• \nMulti-year Training: We will use results from the needs assessment and ongoing input from \nkey stakeholders to develop a multi-year training plan that refects the IRS’s strategic goals \nand objectives. The multi-year training plan will also consider workforce planning, projected \nhiring needs and leadership succession planning. A multi-year training strategy will promote \ncollaboration across the IRS, provide more advanced notice about upcoming training, and \nrealize economies of scale when acquiring external course materials. We will also be able to \ntime training delivery to avoid peak workload periods.\n• \nLeadership Development: We will establish a centralized leadership and management \ndevelopment function within the IRSU to train and develop employees continuously at \neach step of the leadership journey. Developing strong and effective leaders at every level \nis critical to the IRS’s long-term success. We will design learning and career development \nactivities, including assessments, coaching, mentoring, and group and self-directed \nlearning that instill the competencies and behaviors needed to build strong leaders. We will \nalso equip leaders with the skills needed to support employee development and ensure \nleaders are accountable for their employees’ development. Together, supervisors and their \nemployees will design developmental activities and training to track progress along desired \ncareer paths.\n• \nStrategic Sourcing: We will strategically acquire and manage learning platforms, design \nand delivery tools, as well as learning content from external providers and partners. By \nmaking these tools available to each operating division across the IRS, we will eliminate \nduplicative purchases of learning content and reduce overall costs. \n• \nBlended Learning Model: We will use a mix of on-site learning centers and virtual training \nto deliver technical skills. Training may be delivered through traditional classroom training, \nvirtual courses, micro-learning activities (such as videos or podcasts, simulations, job aides, \nwikis or blogs, coaching and on-the-job instruction) and developmental assignments. Our \nblended approach will use adult learning principles and accommodate different learning \nstyles, enhance employees’ training experiences and provide the agency with greater \nability to address changes and challenges in the workplace through training. Training plans \nwill include developmental assignments such as shadow or detail assignments, growth \nopportunities, and coaching or mentoring. We will look to identify the most effective ways to \nsupport employee needs and the delivery of training materials.\n", "79\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n79\n5.2 IRS UNIVERSITY\n5.0 \| TRAINING STRATEGY\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n35 Kirkpatrick’s Four Levels of Training Evaluation, James D. Kirkpatrick and Wendy Kayser Kirkpatrick, 2016, ATD Press.\n36 See Section 5.6 for more details.\nBetter customer \nservice starts with better \nskilled employees.\n—Taxpayer Advocate Service Employee\n• \nExpanded Learning Management System (LMS): We will establish a centralized hub for all \ntraining administration by adding capabilities to our existing LMS under Treasury’s Integrated \nTalent Management (ITM) system that supports the activities and operations of IRSU. The \nimproved system will create a single access point for employees and training personnel to \ndefne and prioritize requirements, register for classes, attend virtual classes and submit \ntraining evaluations. Stored training data will also support reporting, analysis and evaluation. \n• \nOngoing Training Evaluation: We will apply the New World Kirkpatrick Model35 to evaluate \ntraining. By establishing additional guidelines and controls, this model will help us follow best \npractices to improve our training products and capabilities.36\n", "80\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.3 TAXPAYER-FIRST TRAINING\nWith training centralized in the IRS, we will be better able to deliver consistent training with a \nfocus on taxpayers’ needs. All IRS employees will understand how they contribute to the overall \ntaxpayer experience. To support our Taxpayer Experience Strategy, the IRS will educate all \nemployees about our different functions so they can easily navigate across the organization to \nresolve taxpayer issues. \nWe will develop a high-quality, agency-wide, core taxpayer experience curriculum for all \nemployees. This curriculum will focus on organizational awareness to reduce knowledge gaps, \nkey principles of customer service, taxpayer rights (including the Taxpayer Advocate’s role in \ntax administration), early dispute resolution, and research-based behavioral insights. Providing \nour employees with a working knowledge of taxpayer rights is essential to our efforts to provide \nhigh quality taxpayer service. Training on taxpayer rights is a key component of the core \ntaxpayer experience curriculum. We will develop Taxpayer Bill of Rights (TBOR) Training for all \nIRS employees relying on the Taxpayer Advocate Service as a key partner and primary subject \nmatter expert. Taxpayer Bill of Rights training will be delivered to all IRS Employees beginning \nin FY2021\n. This core taxpayer experience curriculum will be supplemented with on-the-job \nresources, references, and job aides. We will also train all employees to resolve taxpayer issues \npertinent to their roles, and tailor role-specifc training to help employees assist taxpayers based \non their occupation and relationship to the taxpayer. This training will also emphasize how \nemployees should guide taxpayers to the appropriate resources to resolve any issues beyond \nthe scope of their knowledge to provide taxpayers with ‘concierge’37 support through all stages of \ntax administration.\nIn addition to updates to the general curriculum for all IRS employees, we’ll update our taxpayer-\nfacing training in phases over the next fve years to provide role-specifc, in-depth knowledge \nof the Taxpayer Experience Strategy and the tools and resources available to assist taxpayers. \nTaxpayer-facing training will be updated as the capabilities outlined in the Taxpayer Experience \nStrategy are introduced. We will also review emerging taxpayer behaviors to improve training \ncontent. This specialized curriculum for IRS assistors will focus on customer service principles, \nproblem-solving and people skills such as active listening, cultural competency and how to use \nplain language to explain complicated concepts. We will teach IRS assistors to use internal \nresources and collaborate with other employees to provide outstanding taxpayer service and will \nuse feedback from taxpayers and other key stakeholders to evolve our training over time. \n37 See Seamless Experience Section 4.4 for additional detail on the concierge model.\n5.0 \| TRAINING STRATEGY\n", "81\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.4 CONTINUOUS LEARNING FOR ALL EMPLOYEES\nTo truly put taxpayers frst, we must promote the personal development and growth of our \napproximately 81,000 dedicated IRS employees. The IRSU will encourage active engagement \nwith employees throughout their careers, ensure consistent access to information, and enable \nadvancement along career paths. Continuous learning is a development concept that involves \nan employee receiving ongoing training throughout their careers. This includes requisite training \nto meet current job demands as well as long term career growth. The goal of the continuous \nlearning approach is to create more ties between these different tools and programs to offer a \nmore cohesive end to end development process.\nAn increased focus on continuous learning will help us:\n• Boost employee engagement\n• Retain a skilled and knowledgeable workforce \n• Expand our ability to forecast and budget for training needs \n• Increase taxpayer satisfaction with exceptional taxpayer service\n• Understand taxpayer diversity\nAs part of our Training Strategy, we will provide training resources that are easily accessible, \nsupport technical training, equip employees to improve their performance, and explore career-\nbroadening opportunities. As explained below, we will create a continuous learning environment \nby focusing on employee training progression, structured career paths, knowledge management, \nand an interactive development environment. \nEmployee Training Progression\nTo better prepare and retain employees, the IRS will offer ongoing training that progresses with \nemployees’ careers. In addition to custom IRS developed content, we will make use of outside \nvendors, external training libraries, external university courses and other relevant sources to \nsupplement training and maintain certifcations. As employees continue to gain experience, \ntraining will focus on more complex tasks and subject matter. To facilitate this progression and \noffer employees the right training at the right time, supervisors and employees will have ongoing \ndiscussions about career goals, training plans, and new learning opportunities. Training will \nfocus on role-specifc skill building as outlined in the graphic below and will be delivered using \ndigital and in-person platforms. \n5.0 \| TRAINING STRATEGY\n", "82\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.4 CONTINUOUS LEARNING FOR ALL \n EMPLOYEES \nFigure 5: Example technical and leadership career paths for a new hire. Individuals could shift from a \ntechnical or leadership path as they progress in their career.\nThe IRS will introduce courses that prepare employees, especially frontline employees, to exhibit \ntop customer service skills. In addition to assigning this curriculum to new employees, the IRS \nwill regularly deliver training at a pre-set cadence to maintain familiarity. We will also continue \nto monitor the taxpayer experience and modify employee training to accommodate changing \nneeds. \nProgressive employee training will:\n• \nBegin by assessing new hires to determine necessary role-specifc training and equipping \nthem to advance in their career with the IRS\n• \nContinue with technical professional education and the development of portable skills \n• \nAdvance toward either mastery as a subject matter expert or a career in leadership following \na well-defned career path \n• \nPreserve agency expertise and resources\nBased on feedback from operations, we will update and customize training regularly. By taking \na holistic approach to developing our employees, we will build subject matter expertise and \nleadership capabilities, enabling employees to control their career paths and provide outstanding \ntaxpayer service. \n", "83\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.4 CONTINUOUS LEARNING FOR ALL \n EMPLOYEES \nEstablished Career Paths\nWhile we support our employees’ professional development, we must also consider our long-\nterm workforce planning goals. We will expand upon ongoing IRS efforts to provide employees \nwith structured, yet fexible career paths aligned with training and developmental activities \nto help them excel in their current role and plan for their future. Employees will also develop \ntransferable skills that allow them to shift roles to meet changing taxpayer needs. For those who \nwant to explore other roles, career paths will give them direction and the ability to evaluate skill \ngaps so that they can successfully transition to new opportunities. We will expand our current \nknowledge management activities and practices, such as virtual libraries, standard operating \nprocedures, knowledge capture, communities of practice, self-help videos, and online tutorials, \nto provide employees with current training resources that improve their technical competencies \nand decision-making and ultimately improve the taxpayer experience. \nMore \ncorporate-level “global” \n training and/or \nlearning opportunities need \nto be provided for employees \nto understand what is \nhappening at the IRS outside \ntheir direct organization.\n—IRS Employee\nThe IRS is committed to providing a clear career path \nfrom novice to executive levels for all employees, \nrecognizing that employees may choose a technical or \nleadership path. We will support employees’ efforts to \nobtain relevant job and professional certifcations and to \nmaintain them through continuing education. \nIRS leadership will review strategic goals and objectives, \nworkforce planning data, results from competency-based \nskills assessments, and employee career goals and \ninterests to determine the number of employees pursuing \ndifferent career paths. We will use this information to \nguide our training plan.\nTogether, supervisors and their employees will design \ndevelopmental activities and training to track progress \nalong desired long-term career paths. As a part of this \nprocess, the IRS will look to invest in technology that allows employees easy access to career \npath and training resources. \nComprehensive Development Environment\nOur Training Strategy will give employees a suite of resources for accessing training and \nknowledge resources at their convenience. These activities will support and supplement learning \nthat occurs via traditional classroom and online, instructor-led courses. The IRS will expand \nour current knowledge management activities and practices, such as virtual libraries, job aids, \ncommunities of practice, self-help videos and online tutorials, to provide employees with \n", "84\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.4 CONTINUOUS LEARNING FOR ALL \n EMPLOYEES \nup-to-date training resources that improve their technical competencies, improve IRS decision-\nmaking, and improve the taxpayer experience.\nWe will foster connections between employees by providing agency-wide forums to share best \npractices and provide coaching opportunities so employees can share their knowledge and \nexperience. For example, as employees acquire new roles, skills or specializations, they will be \nable to engage with groups of subject matter experts, also known as communities of practice. \nThese connections, integrated with existing developmental activities, will improve knowledge \ntransfer across the IRS and support continuous employee learning. We will use “just in time” \ncourses to train employees on procedural changes arising from new legislation or regulatory \nguidance. The graphic below demonstrates how the IRS will integrate its suite of learning \nand development tools into one Comprehensive Development Environment. We will develop \nand deliver competency assessments that will help employees identify areas of strengths \nand weaknesses for personal development. Assessments will allow the agency to target \nareas for additional employee development, reskilling opportunities, and future hiring needs. \nThese integrations provide an ongoing, seamless experience for employees in their learning \ndevelopment and provide opportunities to share that knowledge with other members of the IRS \nworkforce.\nFigure 6: Comprehensive Development Environment\n", "85\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.5 UTILIZING TECHNOLOGY\nTo support the Training Strategy, the IRS will improve technology, subject to available funding, \nto create accessible, high-quality and effective training programs. We will build on lessons \nlearned from the recent COVID-19 pandemic when we adapted classroom training material for \nvirtual delivery and instructors were trained on the technology needed to teach remotely. We \nwill implement new technology to accommodate the administration, delivery and tracking of the \ntraining lifecycle. This technology will support: \n• \nThe development and delivery of training to equip employees to provide excellent taxpayer \nservice\n• A continuous learning environment for employees \n• \nA learning function to provide a consistent, high-quality training experience for all employees \n• The collection and evaluation of data to enhance our training capabilities\nWe will expand the use of Treasury’s Integrated Talent Management system to establish a \ncentralized hub for all training administration that supports the delivery, documentation and \nThe IRS should also consider \ncreating a robust training library \nto make training available to \nemployees on-demand.\n—IRS Employee\nevaluation of learning and development activities. \nEnhancing our existing LMS with additional capabilities \nwill allow us to create a single access point for employees \nand training personnel. Employees will be able to request, \nschedule, access and complete online training and follow-\nup activities designed to reinforce learning and skills \ndevelopment. Employees and supervisors will also use \nthe system to complete evaluation surveys to help the \nIRS improve training. Employees will receive guidance on \naccessing training resources from their manager, mentor \nand leadership team based on their career path and \ngoals. Additionally, we will support leadership in analyzing \ndevelopment opportunities by providing access to critical \norganizational information such as IRS workforce planning data, the training budget, and the \nannual training plan.\nWe will invest in a collaborative virtual training system to integrate with the current LMS. \nTechnology will enable the blended learning approach by creating additional avenues for \nlearning and development activities. Improved technology will be fexible, allowing for the \ndevelopment of new capabilities and enabling training administrators to build plans for \nemployees to grow beyond their current roles.\n5.0 \| TRAINING STRATEGY\n", "86\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.6 MEASURING SUCCESS\nWe will design and evaluate training plans and programs to support our mission, improve training, \nincrease performance goals and enhance the taxpayer experience. Our Training Strategy will \ninclude capturing data to determine the effectiveness of all training with special emphasis on our \ncore taxpayer experience curriculum, Taxpayer Bill of Rights, organizational awareness and early \ndispute resolution. We will monitor data using existing or new key indicators, balanced measures, \ncompliance data and customer ratings to track our progress.\nWe will apply industry standard learning evaluation principles to assess the effectiveness of \ntraining content. The Kirkpatrick Model38,with New World Kirkpatrick Model enhancements, is the \ntraining industry leader in its systematic approach to training evaluation.39 We will incorporate \nthis robust approach to promote a data-rich decision-making environment. The model provides a \nfour-level approach to training: \n38 Kirkpatrick’s Four Levels of Training Evaluation, James D. Kirkpatrick and Wendy Kayser Kirkpatrick, 2016, ATD Press.\n39 U.S. Office of Personnel Management Training Evaluation Field Guide Demonstrating the Value of Training at Every Level \nJanuary 2011\n.\nFigure 7: New World Kirkpatrick Model\n5.0 \| TRAINING STRATEGY\n", "87\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.6 MEASURING SUCCESS\nAccording to the New World Kirkpatrick Model, Level 1 and Level 2 evaluations are equally \nimportant in capturing the employees’ engagement in the course and the skills and knowledge \nthey received from the course. Level 3 evaluations are critical in determining what effect \ntraining has had on employee behaviors and job performance. Level 4 evaluations refect how \nthese behaviors have contributed to organizational improvement. In this approach, the Level 3 \nevaluation serves as the target for effectively delivering on the taxpayer experience.\nLevel 1: Reaction The degree to which employees fnd the training favorable, engaging \n and relevant to their jobs. \nLevel 2: \nLearning \nTests comprehension and the degree to which employees acquire the \nintended knowledge, skills, attitude, confdence and commitment \nbased on their participation in the training. \nLevel 3: \nBehavior \nThe degree to which employees apply what they learned during \ntraining when they are back on the job. \nLevel 4: \nResults \nThe degree to which targeted outcomes such as the taxpayer \nexperience or satisfaction are affected by training programs. \nThe Kirkpatrick evaluation model will provide data from multiple perspectives to evaluate our \nTraining Strategy. Our evaluation approach will refocus on standardizing the use of Levels \n1-3 training evaluations for more consistent data reporting and analysis. The team will identify \nadditional surveys or measures for Level 4 using key indicators to determine if our training \nprograms have a positive effect on the taxpayer experience. We will use this data to enhance our \nemployees’ training experience, improve training content and delivery, and aid decision-making \nabout training resources. Our approach will help us understand the relationship between training \nsuccess and key customer satisfaction and organizational success measures. We will also \nmonitor results from the Office of Personnel Management (OPM) Federal Employee Viewpoint \nSurvey. We will administer short but more frequent Pulse Surveys to increase our agility and \nresponsiveness to employees’ needs. We will use this information to help us provide employees \nwith a high-quality training experience to promote a continuous learning environment and the \ndelivery of a top-quality taxpayer experience. We will have an accountability framework which \nallows us to monitor and track our effectiveness in the following areas: program execution, \nprogram and system evaluation, curriculum design, development and delivery. The framework \nalso allows comparative analysis with respect to competency/skills assessment and training \nevaluation data.\n", "88\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n5.6 MEASURING SUCCESS\nUltimately, our comprehensive Training Strategy represents a holistic approach to improving \nemployee training and development. This will enhance the taxpayer experience and empower \nIRS employees to take ownership of their professional development. Additionally, the investment \nin learning systems will allow us to increase virtual training and provide interactive and cost-\nefficient training nationwide. This will drive greater efficiency by providing training opportunities \nthat yield better performance, preserve organizational knowledge, and improve employee \nretention. We are committed to implementing a training strategy that meets taxpayer needs, \nensures employees are well-prepared for their roles and provides easy access to developmental \nresources. This approach will help employees advance in their careers while also developing the \nskills to backfll vacant positions as needed.\n", "89\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\nEquip employees to provide \noutstanding taxpayer service\nCreate a continuous learning \nenvironment for employees\nExpand our capability to \ndeliver learning and training \nutilizing technology\nCreate an IRS University that drives \nefﬁciency, effectiveness and agility\nImplement governance measures \nto continually improve employee \ntraining experience\nCorporate University that builds on established \nacademies (IRS Leadership Academy, Human \nResources Training Academy, IT University)\nEstablished tools that assess the individual \ntraining needs based on occupation/career path\nTraining curriculum accessible to employees via \nan Integrated Talent Management System \nEnhanced training governance and standards \nthat ensure a high-quality training experience for \nemployees \nAccess to guidance and training resources \nneeded to provide taxpayer service ¬¬and \nto support continuous learning and career \ndevelopment\nGOALS\nVALUE FOR THE EMPLOYEE\nTRAINING STRATEGY\n", "90\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\nIRS University\nTraining Strategy Timeline and Measures\nFY2021-2022\nFY2023-2025\nFY2026-2030\n1-2 years\n3-5 years\n6-10 years\n• Refne training governance \nand training standards \nto ensure a high-quality \ntraining experience for \nemployees \n• Develop Role Specifc Taxpayer \nTraining for taxpayer-facing \nemployees and managers \n• Deliver Position Specifc \nTaxpayer Training for taxpayer-\nfacing employees and \nmanagers\n• A structured collaborative \napproach to ensure our \ntraining activities address \norganizational and individual \nemployee needs, and support \na continuous learning \nenvironment are realized \n• Refne and enhance taxpayer \nfrst training programs based on \nstakeholder feedback\n• Develop career path guides \nand identify accompanying \ntraining curriculums\n• Begin development of \nCompetency Assessments for \nall IRS Positions\n• Establish Competency Based \nCommunities of Practice\n• Make Career Path information \naccessible to employees via an \nIntegrated Talent Management \nSystem\n• Establish Competency \nAssessments for all IRS \nPositions\nTaxpayer First Training\nContinuous Learning \nfor All Employees\n• Defne a model, approach, \nstandards and governance \nto meet current and future \nneeds\n• Eliminate duplicative \ntraining activities (including \nlicenses and subscriptions) \nand centralize training \nacquisitions\n• Identify funding \nrequirements/appropriations \nissues to support stand up \nof the IRS University\n• Implement training \ngovernance \n• Stand up of IRS University\n• Develop training to support \nthe implementation of the \nTaxpayer Experience and \nOrganizational Restructure \nStrategies (Taxpayer First and \nOrganizational Awareness \nTraining)\n• Deliver Taxpayer First, \nTaxpayer Bill of Rights, and \nOrganizational Awareness \nTraining\n• Employees have access to \ntraining resources needed \nto provide taxpayer service \nin their current role, well-\ndefned career paths and \naccess to L&D activities to \nsupport continuous learning \nThe Training Strategy will be implemented in phases that are closely aligned with the implementation \nof the Taxpayer Experience Strategy and plan for changing the IRS Organizational Structure. The \nimplementation includes multiple phases.\nUtilizing Technology\n• IRS University and employees \nhave an end-to-end system \nto support training planning, \ndesign, delivery and evaluation \n(including multi-modal delivery \nplatforms)\n• Identify enhancements \nrequired to Treasury’s \nIntegrated Talent \nManagement System \n• Identify training technology \nrequirements to support \nstrategy implementation\n• Begin acquisition of training \ntechnology and software \n• Implement enhancements \nto the Integrated Talent \nManagement System\n• Complete acquisition of \ntraining technology and \nsoftware to support IRS \nUniversity\n", "91\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\nPhase One Key Takeaways\nPhase one focuses on enhancing IRS capabilities to deliver on an enterprise training approach \nthat supports continuous learning and that equips employees to provide top quality taxpayer \nservice. Phase one activities include: \n• \nThe identifcation of career paths and the identifcation of supporting training curriculum to \nsupport career development\n• \nIdentifcation of corporate training resources (Training Technology, External Providers) to \nsupport the implementation of the strategy\n• \nThe identifcation of enhancements to the IRS Integrated Talent Management system and \ntraining technology to support the training approach\n• \nDefning training governance and training standards to support the implementation of the \ntraining strategy\n• \nCentralizing the acquisition of training tools and resources\n• \nDeveloping a plan to unify the IRS L&E Organizations under an IRS Corporate University \nthat supports the Taxpayer Experience Strategy and plans for changing the IRS \nOrganizational Structure\n• \nRealigning IRS L&E function under the IRS Corporate University \n• \nDeveloping and implementing Taxpayer Service, Taxpayer Bill of Rights and Organizational \nAwareness Training for all IRS employees \n• \nEstablishing a Corporate University that incorporates existing academies (IRS Leadership \nAcademy, Human Resources Training Academy, IT University) \nPhase Two Key Takeaways\nPhase two focuses on establishing an enterprise-wide approach to training and employee \ndevelopment that supports continuous learning via a Corporate University. Key activities will \ninclude: \n• \nI \nmplementing enhancements to the IRS Integrated Talent Management system and training \ntechnology to support the training approach\n• \nMaking career paths and accompanying training curriculum accessible to employees via an \nIntegrated Talent Management System \n• \nImplementing enhanced training governance and training standards to ensure a high-quality \ntraining experience for employees \n• \nEstablishing tools to assess the individual training needs based on occupation/career path \n• \nDeveloping and implementing role specifc taxpayer service training for taxpayer-facing and \nrole specifc training for taxpayer-facing employees\nTraining Strategy Timeline and Measures\n", "92\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\nTraining Strategy Timeline and Measures\nPhase Three Key Takeaways\nDuring the fnal phase we realize our vision of becoming an IRS University that serves one-stop-\nshop that provides a continuous learning environment with accessible resources that equips our \nemployees to provide top-notch Taxpayer Service and supports ongoing career development. \nKey activities include: \n•\nA Corporate University fully implemented with academies focusing on key strategic areas\nsuch as Taxpayer Service, Tax Administration, Technical and Operations Support Activities\nand Leadership Development\n•\nThrough a structured and collaborative approach, we will fully realize a continuous learning\nenvironment that address organizational and individual employee needs\n•\nEnhancements to the IRS Integrated Talent Management system to support the training\napproach and a continuous learning environment are completed\n•\nEmployees have access to the guidance and training resources needed to provide taxpayer\nservice in their current role and to support continuous learning and career development\n•\nAn on-going system is implemented to evaluate and improve training programs and IRS\nemployees training experience\nIRS STRATEGIC \nGOAL(S)\nOBJECTIVE\nMEASURE\nCultivate a well-equipped, \ndiverse, fexible and engaged \nworkforce\nEquip employees to \nprovide outstanding \ntaxpayer service\nReport Kirkpatrick model results for annual taxpayer frst training (Baseline FY2023)\nCreate a continuous \nlearning environment \nfor employees\nPercentage of employees developing through a defned career path; (Baseline FY2023)\nNumber of employee competency assessments established for IRS positions; (Baseline \nFY23)\nDrive increased agility, \nefficiency, effectiveness and \nsecurity in IRS operations\nExpand our \ncapability to deliver \nlearning and training \nutilizing technology\nSuccessful implementation of new training technologies to enhance learning and \nincrease access to training (Baseline EYO FY2021)\nDrive increased agility, \nefficiency, effectiveness and \nsecurity in IRS operations\nCultivate a well-equipped, \ndiverse, fexible and engaged \nworkforce\nCreate an IRS \nUniversity that drives \nefficiency, \neffectiveness and \nagility\nEfficiencies gained through elimination of duplicative programs (TBD) (Baseline FY2023)\nAdvance data access, us-\nability and analytics to inform \ndecision making and improve \noperational outcomes\nImplement measures \nto continually \nimprove employee \ntraining experience\nEmployee and supervisor satisfaction with IRS training re-sources required to provide \nout-standing taxpayer service (TBD) (Baseline FY2023)\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n93\nInternal Revenue Service \| Taxpayer First Act \nS E C T I O N6\nInternal Revenue Service \| Taxpayer First Act \nORGANIZATIONAL \nREDESIGN\nSTRATEGY\nInternal Revenue Service \| Taxpayer First Act \n", "The last major IRS enterprise-wide restructuring resulted from the IRS Restructuring and Reform \nAct of 1998 (RRA ’98), that required a substantial modifcation to our existing geographical \nstructure based on national, regional, and district offices and established organizational units \nserving particular groups of taxpayers with similar needs. The current structure is outlined in Figure \n8 below.\n94\nInternal Revenue Service \| Taxpayer First Act \n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n6.1 INTRODUCTION AND \n EXPLANATION OF \n STRATEGY\n9\n4\nInternal Revenue Service \| Taxpayer First Act \nFigure 8: IRS Organizational Structure as of September 2020\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n95\nInternal Revenue Service \| Taxpayer First Act \n6.1 INTRODUCTION AND EXPLANATION OF \n STRATEGY\nThe workforce as well as the public has \nchanged signifcantly along with technology \nsince our last reorganization almost 20 years ago. \nThe diversity of our customer base as \nwell as our workforce has changed \nalong with that. \n—Robert Ragano, TFAO Executive\nSince RRA ’98, taxpayer expectations have continued to evolve. To ensure that the IRS is \naddressing these changing expectations, our organization needs to adapt to allow for fexibility \naround our taxpayer landscape and improve our taxpayer-facing and internal capabilities. With \nthe passage of the Taxpayer First Act, we have the rare opportunity to reimagine and rebuild \nthe IRS of the future. Committed to our mission and passionate about serving the Nation’s \ntaxpayers, the IRS of the future will serve taxpayers even more efficiently with an enhanced \nfocus on taxpayer rights and strong career opportunities for our employees. \nThe Organizational Redesign Strategy \nwould enable our agency to streamline \noperations by removing silos and \nadapting to changing taxpayer \nexpectations. The strategy addresses \nexisting challenges throughout the \nagency and focuses on enhancing the \ntaxpayer experience and employee \nexperience and improving operational \nefficiencies. The Organizational \nRedesign Strategy, and all included \nrecommendations, is intended to \nfacilitate cultural change, increase trust \nand improve understanding and ease \nfor the American taxpayer. \nWhile our high-level strategy will set the tone for signifcant structural changes, we acknowledge \nthat further detailed analysis is needed. We will develop additional detail on our organizational \nstructure and operating model by creating an Organizational Blueprint Report which will be \ndelivered in phase two of this work. \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n96\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TAXPAYER EXPERIENCE STRATEGY\n6.2 PROPOSED FUTURE ORGANIZATIONAL \n STRUCTURE AND DIVISIONS\nOur proposed organizational structure is designed to support and sustain the Taxpayer Experience \nand Training Strategies. The Commissioner and the new Senior Leadership Team would drive \ncollaboration, build internal operational efficiencies, and implement the multi-year Taxpayer \nExperience and Training Strategies. Figure 9 shows the agency’s new structure with the direct \nreports to the Commissioner and their direct reports. \nFigure 9: Notional Future IRS Organizational Structure\nEach Section below outlines our proposed new structure, the organizational challenges that we \naim to address, as well as descriptions and details of the offices included within the structure. \nTogether, the sections explain our proposed changes and their potential benefts.\n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n97\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TAXPAYER EXPERIENCE STRATEGY\n6.3 \nCOMMISSIONER DIRECT REPORTS\nOur new structure would have one Deputy Commissioner, one Chief of Staff, and 10 Executive \nOfficers that report directly to the Commissioner. These direct reports will serve as the Senior \nLeadership Team and would lead the following organizations: Taxpayer Experience Office, \nIRS Independent Office of Appeals, Communications Office, Office of Chief Counsel, Taxpayer \nAdvocate Service, Relationships and Services Division, Compliance Division, Enterprise Change \nand Innovation Division, Operations Management Division, and the Information Technology \nDivision. The Commissioner and the Senior Leadership Team would work collaboratively to set the \nstrategic direction and lead the numerous executives that oversee day-to-day operations.\nFigure 10: High-level Notional Depiction of the Senior Leadership Team\n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\nWe seek to shift from our current hierarchical structure to a fatter headquarters leadership \nstructure and decision-making body. While the total number of direct reports to the \nCommissioner will increase under the new organizational structure, the Senior Leadership \nTeam40 would be reduced signifcantly. A smaller overall team allows for a more open style \nof discussion and a more effective environment to brainstorm solutions. Decisions will be \nwell-informed by research and data supporting the best practices for improving the taxpayer \nexperience, protecting taxpayer rights, enhancing the employee experience, increasing program \neffectiveness and realizing operational efficiencies. Strategic initiatives will be clearly defned \nand well-coordinated; communications, both internally to the workforce, and externally to our \ntaxpayers will be in plain language and easy to understand. The leadership culture will embrace \nshared accountability and foster innovation and collaboration.\n40 In the new organizational structure, the Senior Leadership Team will serve in place of the current Senior Executive Team.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n98\nInternal Revenue Service \| Taxpayer First Act \nFigure 11 provides an alternate visual representation of how the Senior Leadership Team would \ncollaboratively work together. The organizations reporting directly to the Commissioner are \ndescribed in greater detail below. Current operations would be rescoped to deliver an enhanced \ntaxpayer experience and drive operational efficiencies.41 \n6.3 \nCOMMISSIONER DIRECT REPORTS\n41 See Appendix 9.7 for previous oversight recommendations from offices such as the Chief Risk Office, TIGTA, and GAO we \nfeel align to, validate, and support some of our proposed changes. \nFigure 11. Alternate visual representation for how the Senior Leadership Team will collaboratively \nwork together. Protecting Taxpayer Rights and holistic Taxpayer Experience Activities will \nencapsulate all leadership decisions and activities. Statutorily required ofces are indicated by a \ndarker shade of blue.\ncollaboratively work together. The organizations reporting directly to the Commissioner are \ndescribed in greater detail below. Current operations would be rescoped to deliver an enhanced \ntaxpayer experience and drive operational efficiencies.41\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n99\nInternal Revenue Service \| Taxpayer First Act \n6.3 \nCOMMISSIONER DIRECT REPORTS\nNew Top-Level Organizations Reporting to the Commissioner\nThe Deputy Commissioner, Internal Revenue Service would report to the Commissioner, \nreplacing the current dual deputy structure. The Deputy would serve in an advisory role to \nthe Commissioner and will serve as the Commissioner’s second in command. This position \nshould be flled by an agency career employee who has demonstrated broad understanding \nand leadership of the multiple areas at the IRS. This would provide consistency and continuity \nas Commissioners, who are political appointees, transition in and out of the agency. While \nthe Deputy would not have any direct reports, they would act as a representative for the \nCommissioner during periods of transition and may manage the members of the Senior \nLeadership Team through delegation.\nIn this model, the IRS Commissioner would be empowered to use the Deputy position based \non their individual leadership style and emerging agency needs. If the Commissioner wants \nmore direct involvement in the day-to-day operations, the Deputy’s role would be more advisory, \npotentially handling some of the Commissioner’s other duties to free the Commissioner to fully \nengage in setting strategic direction and overseeing the agency’s operations. If an emerging \ncrisis or signifcant legislative issue requires the Commissioner’s primary focus, the Deputy \ncould assume more direct involvement in overseeing the operations.\nAs delegated, the Deputy Commissioner may hold the same authority of the Commissioner \nwhile still being accountable to the Commissioner and reducing additional layers of leadership. \nA key feature of this structure is the introduction of the Taxpayer Experience Office. Comprised \nof a relatively small staff of experts in the areas of customer experience, research, behavioral \nanalytics, human-centered design and service delivery with the ability to provide other \norganizational units with information on changing taxpayer expectations, industry trends and \nways to apply customer service best practices within the framework of IRS operations and \nfederal limitations. The Taxpayer Experience Office would focus on continuously improving the \ntaxpayer experience across all interactions with the IRS.\nThe Chief Taxpayer Experience Officer would lead the Taxpayer Experience Office and would \nwork closely with their peers across the agency, including the National Taxpayer Advocate \n(NTA). The Taxpayer Advocate Service will help to leverage research studies and systemic \nmonitoring techniques to inform real-time improvements to the taxpayer experience and develop \nlonger term strategies, while also playing a key role in informing the continuous feedback loop \ndescribed in the Taxpayer Experience Strategy. The Chief Taxpayer Experience Officer would \nhold primary accountability for overseeing implementation of the Taxpayer Experience Strategy, \ncontinuously monitoring, setting strategic direction and establishing priorities for improving the \ntaxpayer experience while also identifying taxpayer trends and determining how improvements \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n100\nInternal Revenue Service \| Taxpayer First Act \n6.3 \nCOMMISSIONER DIRECT REPORTS\ncan be implemented across the agency. They would be deeply focused on the taxpayer \nexperience - conducting research, engaging both internal and external stakeholders in dialogue \nand listening sessions, gathering data and monitoring industry trends and best practices. The \nChief Taxpayer Experience Officer would employ that information to drive strategic direction and \nidentify continuous improvement opportunities for the IRS taxpayer-facing programs. \nThe Relationships and Services Division would bring together all taxpayer-facing service \noperations and activities, serving as the front door to the IRS for all taxpayers and other \nstakeholders. This division would be responsible for end-to-end service delivery and relationship \nmanagement while sustaining the value of having some aspect of taxpayer segmentation and \nspecialization within the program areas. See Section 6.4 for additional detail.\nThe Compliance Division would include all exam functions and collection operations in addition \nto the Criminal Investigation and Whistleblower Office. This division would be focused towards \nmore efficient operations and providing consistent outcomes for resolving taxpayer compliance \nissues. See Section 6.5 for additional detail. \nThe Relationships and Services and Compliance divisions would be responsible for \nimplementing taxpayer experience improvements, continuously communicating with the \nTaxpayer Experience Office on areas for improvement and success.\nThe Enterprise Change and Innovation Division would plan and oversee the implementation \nof enterprise-wide initiatives working with leadership across the agency to coordinate annual \nstrategic planning activities to streamline decision making and enable the agency to set and \nmeet its short and long-term strategic goals. The Chief Taxpayer Experience Officer would work \nalongside the offices within this division to ensure taxpayer experience improvement initiatives, \nand fndings, are considered in strategic planning activities. See Section 6.6 for additional detail.\nThe Operations Management Division would be responsible for coordinating and leading all \nmission-support operation functions across the IRS and would include the Chief Risk Officer \nand Chief Diversity Officer. The Chief Risk Officer and Chief Diversity Officer will have dotted line \nreporting to the Commissioner. See Section 6.7 for additional detail. \nThe Information Technology Division would include distinct functions focused on \nmodernization to better respond to taxpayer demand for enhanced information technology \nsolutions and online services. Protecting taxpayer data would continue to be a priority for the \ndivision, ensuring protection against evolving threats. See Section 6.8 for additional detail. \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n101\nInternal Revenue Service \| Taxpayer First Act \n6.3 \nCOMMISSIONER DIRECT REPORTS\nThe [previous] model created \nstovepipes, silos, and conficts \nover resources and priorities \nacross operating divisions and \nsupport functions.\n—Association of Former \nInternal Revenue Executives\nThe Communications Office, as a direct report to the Commissioner, would have a narrower \nset of responsibilities more focused on agency level media and public relations and interactions \nwith Congressional offices at the national level. This new Communications Office would work to \nconsistently improve public perception of the IRS and increase taxpayer awareness and trust. \nThis office would also support the agency’s operating strategies to ensure that communications \nwith taxpayers, the Congress and other stakeholders are consistent and coordinated IRS-wide. \nElements of today’s Communications and Liaison organization would be shifted to the Outreach \nand Education office within the Relationships and Services Division to more directly assist \ntaxpayers and expand upon the agency’s social media strategy. Some aspects of the current \nCommunications and Liaison organization would also move to the Third-Party Relationships \noffice also under the Relationships and Service Division to ensure even greater and stronger \npartnerships with the practitioner community and the local/feld Congressional offices.\nThe IRS Independent Office of Appeals structural model complies with Section 1001 of the \nTaxpayer First Act. The Taxpayer First Act required that the IRS establish an office that: “resolve \nFederal tax controversies without litigation which is fair and impartial to both Government and \nthe taxpayer”\n, and “enhance public confdence in the integrity and efficiency of the Agency”\n, and \nbe a direct report to the IRS Commissioner. The IRS Independent Office of Appeals must also \nbe “…under the supervision and direction of an official to be known as the Chief of Appeals.” No \nadditional future changes for the Independent Office of Appeals are proposed.\nUnchanged Organizations Reporting to the \nCommissioner\nThe National Taxpayer Advocate’s (NTA) role remains \nunchanged in the new organizational structure. The \nNational Taxpayer Advocate will continue to lead the \nTaxpayer Advocate Service and report directly to the \nCommissioner. Taxpayer Advocate Service employees \nwill continue to assist taxpayers who are experiencing \neconomic harm, who are seeking help in resolving tax \nproblems that have not been resolved through normal \nchannels, or who believe an IRS system or procedure \nis not working as it should. Taxpayer Advocate Service \nemployees share the responsibility with all IRS personnel \nto ensure taxpayer rights are considered and protected in \nall cases. The National Taxpayer Advocate and the Tax Advocate Service would work closely with \nthe new Taxpayer Experience Office to provide key insights into systemic breakdowns and other \nemerging issues impacting the taxpayer experience.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n102\nInternal Revenue Service \| Taxpayer First Act \n6.3 \nCOMMISSIONER DIRECT REPORTS\nThe Office of Chief Counsel will continue to serve as chief legal advisor to the Commissioner \non all matters pertaining to the interpretation, administration, and enforcement of the Internal \nRevenue Code. The Office of Chief Counsel provides services including published guidance, \nlitigation, legal advice, and training designed to educate taxpayers, reduce burden, and simplify \ntax administration. The Office of Chief Counsel also plays a critical role in interacting with \nexternal stakeholders and gathering input to help shape the regulations and other published \nguidance provided to taxpayers.\nThe Chief of Staff will continue to provide critical strategic and operational support to the \nCommissioner’s office. There will be no signifcant change from current operations. The \nChief of Staff will support the Commissioner to ensure that agency actions requiring priority \nattention are addressed in a timely and effective manner. This office will aid the Commissioner \nin navigating demands on the agency and provide guidance to the Commissioner and Deputy \nin the execution of day-to-day operating activities. The Chief of Staff Office will ensure that the \nCommissioner, Deputy, and Senior Leadership Team have the appropriate information to make \ndecisions and will provide the Commissioner the necessary leadership information to effectively \nguide the agency.\nAdding Value\nIncreased Accountability: This reporting structure provides a clear delineation of senior \nexecutives responsible for service and compliance operations (currently taxpayer service \nand compliance activities are dispersed across the various business units) and provides the \nCommissioner with information related to the current state of organizational initiatives and \npotential areas of concern. It also enables quick escalation of key issues or decisions to the \nCommissioner. The Commissioner can also continue to communicate organizational priorities \ndirectly with the Assistant Commissioners of Relationships and Services, Compliance, \nEnterprise Change and Innovation, Operations Management and Information Technology.\nEnhanced Innovation: Through a strong emphasis on cross-agency collaboration amongst \nevery direct report and their divisions and offices, there will be increased focus on innovation \nthroughout the organization. With a clear line of sight into both long-term strategy (e.g., Taxpayer \nExperience, Enterprise Change and Innovation) and current operational challenges (e.g., \nRelationships and Services, Compliance, Operations Management, Information Technology), \nthe Commissioner will have clear insight into key areas best positioned for innovative \napproaches or technology that will address existing challenges and help us meet our \n long-term goals. \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n103\nInternal Revenue Service \| Taxpayer First Act \n6.3 \nCOMMISSIONER DIRECT REPORTS\nStrengthened Communication and Improved Awareness: The Communications Office would \ncoordinate across the IRS to understand the nuances of each division or office and effectively \nshare progress, wins, and new services with the Congress, the White House, and media outlets. \nWorking with the Taxpayer Experience Office, the Communications Office will share information \nabout taxpayer service pilots and new initiatives. The Communications Office will be responsible \nfor effectively disseminating key messages from the Commissioner and other leadership to \ninternal and external audiences. With a reduced scope of responsibilities, this office will be able \nto focus more intently on internal and external agency level communications.\nImproved Taxpayer Experience: The Taxpayer Experience Office creates a dedicated \norganization responsible for driving enterprise-wide strategy to improve the taxpayer experience \nacross all taxpayer interactions. The Taxpayer Experience Office would ensure a consistent \nvoice and experience across all taxpayer segments by developing comprehensive taxpayer \nexperience guidelines and expectations. The Chief Taxpayer Experience Officer’s responsibilities \nextend beyond taxpayer interactions with the Relationships and Services Division, which would \nbe the originating source for most taxpayer interactions. The Chief Taxpayer Experience Officer \nwill also seek to drive consistency across many different areas, including working within the \nCompliance Division, the IRS Independent Office of Appeals, Taxpayer Advocate Service and \nthe Office of Chief Counsel to facilitate the use of new tools for communicating with taxpayers \nand their representatives. We envision the Chief Taxpayer Experience Officer as a subject matter \nexpert with the ability to provide other organizational units with information on changing taxpayer \nexpectations, industry trends and ways to apply customer service best practices within the \nframework of IRS operations and federal limitations. \nThe Taxpayer Experience Office would continuously monitor taxpayer and stakeholder feedback \nand identify emerging trends across industry innovations and taxpayer behaviors. The office \nwould also identify opportunities in existing taxpayer-facing processes and drive continuous \nimprovements in real time. Furthermore, this office would help to eliminate systemic breakdowns \nbefore they can have a negative impact on taxpayers. \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n104\nInternal Revenue Service \| Taxpayer First Act \n6.3 \nCOMMISSIONER DIRECT REPORTS\nPrioritized Taxpayer Rights: The National Taxpayer Advocate will continue to play a key \nrole in ensuring taxpayer rights are protected, helping to inform taxpayer experience and \nother agency strategies accordingly. In addition, the Taxpayer Experience Strategy, Training \nStrategy, and Organizational Redesign Strategy were developed to not only improve our \nservice and work to eliminate taxpayer challenges, but to further ensure that taxpayer rights \nwere protected. Changes made to the Relationships and Services, Compliance, Enterprise \nChange and Innovation, Operations Management, and Information Technology Divisions \nspeak to opportunities to improve operational efficiencies, collaboration, and internal security. \nAs we improve efficiencies, the quality of service to the taxpayer will improve, consistent with \nand in support of the Taxpayer Bill of Rights. Additionally, the Taxpayer First Act codifed the \nresponsibility of an IRS Independent Office of Appeals led by the Chief IRS Independent Office \nof Appeals, reporting directly to the Commissioner. The IRS Independent Office of Appeals will \ncontinue to oversee effective procedures within the appeals process, and, most importantly, \nensure this process is fair and impartial to beneft all taxpayers. \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n105\nInternal Revenue Service \| Taxpayer First Act \nWorking together with the Strategic Planning and \nLegislative Implementation Office and the Chief Taxpayer \nExperience Officer, the Assistant Commissioner of \nRelationships and Services would implement the \nvision of the Taxpayer Experience Strategy. With all \ntaxpayer-facing service channels under one division, the \nAssistant Commissioner of Relationships and Services \nwill be uniquely suited to oversee implementation of a \nservice delivery model that, integrates digital, telephone, \nvirtual and face-to-face channels seamlessly. They would \ndeliver the services to taxpayers across all channels in \naccordance with the strategic direction set out by the \nChief Taxpayer Experience Officer and agency leadership. \nLeadership in this division will continually evaluate \nbusiness processes to identify and implement performance \nimprovement opportunities. They would engage regularly \nwith the Compliance Division to deliver a holistic taxpayer \nexperience, facilitating increased voluntary compliance \nwhile reducing taxpayer burden. As a direct report to \nthe IRS Commissioner, the Assistant Commissioner \nof Relationships and Services would ensure efficient \nfow of information impacting the taxpayer experience \nto the Commissioner and, to all members of the Senior \nLeadership Team. Employees in this division will be well-\ntrained to resolve taxpayer inquiries and will be equipped \nwith the knowledge and tools needed to identify the right \nresources and personnel to resolve taxpayer issues. \n6.4 RELATIONSHIPS AND SERVICES DIVISION\nFigure 12: High-level Notional Relationships & \nServices Division.\nThis division will include six functions dedicated to delivering services and information: Assisted \nServices, Digital Services, Outreach and Education, Third-Party Relationships, Identity \nTheft / Fraud, Submission Processing and Privacy.\n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n106\nInternal Revenue Service \| Taxpayer First Act \n6.4 RELATIONSHIPS AND SERVICES DIVISION\nThe Assisted Services Office would be responsible for services delivered by IRS employees \nvia walk-in centers and toll-free telephone lines as well as online text and video chat. The \nAssisted Services Office would include identity theft victim assistance. Assisted Services \nwould continue to work closely with the Identity Theft/Refund Fraud office. This office would be \naccountable for implementing the Seamless Experience capability described in the Taxpayer \nExperience Strategy, integrating channels and facilitating taxpayers’ ability to start their journey \nin one channel and seamlessly fow to the channel or area most suited to resolving their issue. \nThis office would connect employees across channels and across the agency to holistically \nresolve taxpayer inquires in the most efficient and effective way possible.\nThe Digital Services Office would be responsible for leading programs and capabilities \ncentered on delivering services and information through digital channels. Working with the \nAssistant Commissioner of Enterprise Change and Innovation, the Chief Taxpayer Experience \nOfficer, and the Assistant Commissioner Chief Information Officer, this function would evaluate, \ntest and implement new digital service options to improve the taxpayer experience. Integrating \noversight of our digital service environment will give the IRS a more complete view across the \ntaxpayers’ digital experience. Co-locating this function with the Assisted Services, Outreach and \nEducation and Third-Party Relationships Offices would allow for digital solutions to be leveraged \nacross those other service delivery environments. The Digital Services Office would continuously \nmonitor the taxpayer experience across the digital environment, identifying breakdowns \nand improvement opportunities in real time. This office would consist of the capabilities and \nprograms currently housed within Online Services, and parts of the Joint Operations Center. \nThis office would work closely with the Assistant Commissioner Chief Information Officer as well \nas compliance functions to ensure an enterprise-wide approach to digital communication with \ntaxpayers and stakeholders. This office will also execute on pieces of the Taxpayer Experience \nStrategy related to Expand Digital Services and a Seamless Experience.\nThe Outreach and Education Office would be dedicated to taxpayer education and outreach, \nsupporting both service and compliance programs. This office would work closely with Third-\nParty Relationships to deliver volunteer-based programs in support of return preparation and \ntaxpayer education (e.g., Volunteer Income Tax Assistance (VITA) and Tax Counseling for the \nElderly (TCE) programs). Taxpayer and stakeholder outreach activities currently conducted in the \nIRS’s Media and Publications and Communications and Liaison Offices would move to Outreach \nand Education. This function would execute the IRS’s Social Media Strategy, developing and \nusing new tools and resources to reach taxpayers on the platforms they use most frequently. \nIntegrating all outreach and education activities into a single function would provide us with the \nopportunity to eliminate redundant activities, better leverage best practices, realize economies of \nscale and amplify our reach and effectiveness with messaging spanning across our service and \ncompliance programs. This office would be responsible for executing on the Proactive Outreach \nand Education capabilities outlined in the Taxpayer Experience Strategy.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n107\nInternal Revenue Service \| Taxpayer First Act \n6.4 RELATIONSHIPS AND SERVICES DIVISION\nThe Third-Party Relationships Office would be responsible for delivering program and \ncapabilities specifcally dedicated to furthering relationships and partnerships across the tax \necosystem. Acknowledging that the IRS cannot effectively administer our complex tax system \nand serve our broad and diverse customer base alone, this function includes groups that interact \nwith tax professionals and other stakeholders across the public, private and non-proft sectors to \ncollaborate on delivering services and information to taxpayers. This office would be responsible \nfor engaging our Community of Partners, developing, nurturing and integrating partnerships \nwhile creating forums to facilitate dialogue. Together with our partners, this office would support \nimplementation of new initiatives, programs and legislation.\nAs we look inward, \nwe’re going to keep coming back to \nour organizational structure and \nwhether it is actually enabling \nand empowering us to have the \nmost successful interaction with \nthe taxpayer possible.\n— Lia Colbert, TFAO &YFDVUJWF Lead \nThe Identity Theft / Fraud Office would \nintegrate identity theft workstreams across \nthe agency. This office would work closely \nwith Assisted Services to meet the needs \nof victims of identity theft. Integrating our \nvarious identity theft assistance, prevention \nand resolution activities would help improve \ninformation sharing, streamline operations, \nmanage fraud risks, and further strengthen \nthe agency’s efforts to prevent identity theft \nfor all taxpayer groups. This office would \nwork closely with Third-Party Relationships \nto facilitate the Security Summit and Identity \nTheft Refund Fraud Information Sharing \nAssistance Center (IDTRF-ISAC). \nThe Submission Processing Office will continue to be responsible for processing tax returns \nand related documentation, including paper returns, electronic submissions, tax payments, and \nrefunds. One change to their scope of responsibilities would be that the organization would \noversee mail processing across all IRS facilities which includes, generating opportunities for \nincreased consistency, streamlined processes, identifcation and expansion of best practices \nas well as, acceleration of our enterprise-wide digitalization strategy. This office would assume \noversight for all “processing” activities across the IRS including paper power of attorney forms, \ntranscript requests (e.g., through the Income Verifcation Express Service and Get Transcripts \nby Mail requests), Individual Tax Identifcation Numbers and applications for participation in the \neServices suite of digital offerings for tax professionals.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n108\nInternal Revenue Service \| Taxpayer First Act \n6.4 RELATIONSHIPS AND SERVICES DIVISION\nThe existing Privacy, Governmental Liaison and Disclosure (PGLD) Office will be realigned \ninto the Relationships and Services Division as Chief of Privacy. This reaffirms the agency’s \ncommitment to taxpayer privacy. It mirrors Treasury’s Privacy, Transparency and Record \norganizational design. It also maintains organizational balance between the Chief of Privacy \nand the Assistant Commissioner Chief Information Officer where the Chief of Privacy is \nresponsible for the vision, strategy and operational use of personal information and the Assistant \nCommissioner Chief Information Officer is responsible for the systems where the use takes \nplace.\nAdding Value\nThe Relationships and Services Division structural component, coupled with implementation \nof the Taxpayer Experience Strategy, brings integration across program areas, creates a more \nholistic approach to service delivery and facilitates swift and complete issue resolution. This \nstructure creates one division responsible for end-to-end service delivery and relationship \nmanagement, while sustaining the value of having some aspect of taxpayer segmentation and \nspecialization within the program areas. Under the omni-channel service delivery model and the \nconcierge concept from the Taxpayer Experience Strategy, this division would serve as the entry \npoint for all taxpayer and stakeholder interactions. Employees in Relationships and Services \nwould collaborate with their peers across the IRS to resolve taxpayer inquiries and issues in \nthe most expeditious and effective manner, while imposing the least amount of burden on the \ntaxpayer possible.\nAlignment to Strategies: Working together with the Taxpayer Experience Office, the \nRelationships and Services Division would hold primary accountability for executing the \nTaxpayer Experience Strategy including, Digital Services, Proactive Outreach and Education, \nand Community of Partners. This ensures enterprise level decision making for investments \ntoward key taxpayer service operations and coordination across the agency for continuity in \nexternal / internal communications. This division also demonstrates the IRS’s priority of putting \ntaxpayers frst and serving all stakeholders quickly and effectively.\nPromoting Efficiencies: This division centralizes taxpayer service operations across all \ntaxpayer segments, eliminating redundant processes, coordinating investments in new \ntaxpayer-centric initiatives, and effectively allocating resources across the agency in support \nof all taxpayer segments and stakeholders. This model also reduces burden on taxpayers and \nstakeholders to navigate a maze of service channels to determine the one most suited to their \nneeds.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n109\nInternal Revenue Service \| Taxpayer First Act \n6.4 RELATIONSHIPS AND SERVICES DIVISION\nClearly Identifed Service Channels: Functions dedicated to assisted services, digital services, \noutreach and education, and third-party relationships provide more streamlined services to \nour taxpayers. Employees in these functions would have the appropriate tools and access to \ninformation to better assist taxpayers and guide stakeholders to the right area of the IRS to \nresolve their issue.\nImproved Integration Across Channels: The clearly identifed service channels would also \nbe more integrated allowing taxpayers to fow from one channel to another when needed. \nPlacing Digital Services and Assisted Services Offices in the same division will position online \nactivities closer to phone operations and allow the IRS to more effectively allocate and reallocate \nresources across the two functions. The IRS would be better positioned to transition taxpayer \nneeds from phones to electronic / digital sources of communications, and address gaps in \nreaching specifc taxpayer segments or underserved communities. Over time, this integration \nwould enable the IRS to develop and institute measures that better refect the taxpayers’ holistic \njourney across multiple touchpoints with the IRS.\nStreamlined and Improved Identity Theft/Fraud Activities: This division would further \nstreamline and improve our identity theft and fraud activities. It would establish an organization \nwhich would work closely with the Information Technology Division to continue the IRS’s work \nto identify and implement new technology, innovation, policy and programs to prevent identity \ntheft and fraud. Leveraging the Continuous Feedback Loop and advanced Data Management \nand Analytics envisioned by the Taxpayer Experience Strategy, identity theft activities would be \nbetter informed by real time data drawn from case histories, contacts with taxpayers and other \nsources across the agency and beyond. Having Identity Theft/Refund Fraud and Third-Party \nRelationships in a single division further facilitates the continuation of the highly successful \npublic-private partnership through the Security Summit. Integrating our identity theft work with \nthe Outreach and Education Office provides increased opportunities to educate taxpayers and \ntax professionals on steps they can take to protect themselves from identity theft and resolve \nissues if they fall victim. \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n110\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TAXPAYER EXPERIENCE STRATEGY\n6.5 COMPLIANCE DIVISION\nFigure 13: High-Level Notional Compliance Division.\nA key IRS responsibility is to ensure taxpayers \ncomply with the tax laws and voluntarily meet their \ntax obligations. Our current organizational structure \nfor Compliance and Enforcement lacks a centralized \ncompliance function. Compliance activities occur \nmainly within the four business units that perform \nsimilar functions but have distinct taxpayer segments; \nWage and Investment, Small Business/Self Employed, \nLarge Business and International, and Tax Exempt/\nGovernment Entities. The business units focus on \nexaminations, collection, and within TE/GE the Rulings \nand Agreements functions. Our future structure would \nestablish a unifed Compliance Division, creating \na centralized compliance function geared towards \nensuring more efficient operations and providing \nconsistent outcomes for resolving taxpayer compliance \nissues. This division would also ensure a focused \napproach to addressing emerging compliance issues. \nThis division would include fve functions dedicated \nto coordinating and leading all IRS compliance and \nenforcement activities across the agency: Compliance, \nWhistleblower, Criminal Investigation, Exam and \nCollection.\nThe Assistant Commissioner of Compliance would manage consolidated exam functions and \ncollection operations along with overseeing Criminal Investigation and the Whistleblower Office. \nThe Compliance Division would also include Rulings and Agreement functions from TE/GE due \nto its technical nature and compliance with statutory requirements. The Compliance Division \nwould promote efficiencies, reduce duplicative activities and fragmentation, empower employees \nand continue to build talent. \nThe Chief Compliance Officer would work directly with the other leadership members of \nthe Compliance Division to develop an integrated comprehensive compliance strategy and \nexam plan. Working in collaboration with the Chief Data Officer from the Enterprise Change \nand Innovation Division, the Chief Compliance Officer would identify and track evolving \ntaxpayer behaviors across all taxpayer segments in order to implement innovative compliance \nsolutions. The Chief Compliance Officer would also collaborate with the new Chief Taxpayer \nExperience Officer to ensure information on taxpayer satisfaction, expectations and trends \n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n111\nInternal Revenue Service \| Taxpayer First Act \n6.5 COMPLIANCE DIVISION\n42 See Appendix 9.7\n.7 for additional rationale for the placement of the Criminal Investigation Office within the Compliance \nDivision.\nis shared. This coordinated effort would identify taxpayer segments in need of proactive \noutreach and education, as well as additional employee training needs. Along with the Chief \nTaxpayer Experience Officer, the Chief Compliance Officer would also work with the Assistant \nCommissioner of Relationships and Services to design and implement taxpayer-facing \ncapabilities, such as chat, secure document exchange, appointments, across compliance \noperations in order to proactively address recurring taxpayer issues to ensure a fair and \nprofessional audit process that anticipates and resolves frequent taxpayer issues, questions, or \nconcerns. \nThe Whistleblower Office will have no signifcant changes to its responsibilities from its current \noperations within the present-day organizational structure. The Whistleblower Office will retain its \ncurrent critical position, reporting directly to the Assistant Commissioner of Compliance. \nThe Criminal Investigation Office will have no signifcant changes to their responsibilities from \nits current operations within the present-day organizational structure. The Criminal Investigation \nOffice would report directly to the Assistant Commissioner of Compliance. For more information \non the position of Criminal Investigation Office within the Organizational Structure, refer to the \nAppendix Section 9.7\n.7\n.42 \nThe Exam Office will consolidate exam operations and processes that currently span across \nmultiple business units. This office will be responsible for all examination processes across \nall taxpayer segments but would maintain some degree of specialization to address unique \ntaxpayer needs. The Exam Office will work to document best practices and behavioral trends \nrelated to the examination processes across all taxpayer segments and identify opportunities to \nshare knowledge across the Compliance Division to improve operational efficiencies. \nThe Collection Office will continue to be responsible for collection activities across all taxpayer \nsegments. Alongside the consolidated Exam Office, the Collection Office will be better positioned \nto coordinate priorities and learn about taxpayer behavioral trends resulting in more directed \neducation to taxpayers. The Collection Office will also document best practices and behavioral \ntrends to share with the Exam Office and help inform compliance strategies across the division.\n \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n112\nInternal Revenue Service \| Taxpayer First Act \n6.5 COMPLIANCE DIVISION\nAdding Value\nPromoting efficiencies and reducing duplication and fragmentation: The Compliance \nDivision consolidates compliance functions across taxpayer segments into one division, \nminimizing the duplication of oversight, planning, services and responsibilities and developing \ncommunities of expertise. This will structure facilitate the development of a compliance strategy \nthat considers compliance issues across all taxpayer segments and enables Exam and \nCollection leadership to identify compliance related behavioral trends across taxpayer segments. \nThis coordination ensures reduced variability in compliance processes and a more consistent \ntaxpayer experience. Ultimately, this consolidation aims to reduce duplicative activities related \nto strategic planning, issue identifcation, work plan development, case selection, performance \nmonitoring, and research, where possible, across taxpayer segments.\nEmpowering employees and building talent: Combining compliance functions creates a \npotential career path for compliance employees to follow and advance their skills by beginning \nwith less complex income tax audits and progressing to more complex work. This change \nwould also enable a consistent approach to onboarding and coordinated training across key \ntopics (e.g., emerging issues training, manager training), and ensure that the compliance \nworkforce has access to professional development resources and tools. Additionally, combining \nexamination functions would empower employees to make decisions through a clearer \nunderstanding of how their goals and responsibilities support enterprise-wide examination \npriorities.\nMaintaining position of Criminal Investigation: Maintaining current positioning will help \nreduce the potential risk of public perception that the outcome of criminal investigations may \nbe politically infuenced. This structure also offers stability across presidential administrations, \nenabling long-term strategic planning and ability to achieve our long-term goals. Lastly, reporting \ndirectly to the Assistant Commissioner of Compliance allows for an integrated comprehensive \ncompliance strategy that includes a more balanced perspective on the IRS’s enforcement \nchallenges and drives compliance to include the Criminal Investigation Office in strategic \napproaches to tax abusive schemes. \n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n113\nInternal Revenue Service \| Taxpayer First Act \n6.6 ENTERPRISE CHANGE AND INNOVATION \n DIVISION\nThe Enterprise Change and Innovation Division \nwould serve as the strategic planning and integration \nrole across the agency, utilizing data management, \nanalytics and business process improvement best \npractices to identify and implement enterprise-wide \ninitiatives that would enable the IRS to be more \nefficient and effective in serving taxpayers and \nadministering the tax code. Most immediately, this \ndivision will coordinate the Taxpayer Experience \nOffice and Human Capital function to implement \nthe TFA Taxpayer Experience, Training, and \nOrganizational Redesign Strategies through program \nmanagement, governance, change management \nand other tactical implementation functions over \nthe coming months. The Assistant Commissioner of \nEnterprise Change and Innovation would integrate \nall agency strategies and operational priorities \ninto an agency level strategic plan. While the Chief \nTaxpayer Experience Officer would be primarily \nresponsible for the Taxpayer Experience Strategy, the \nFigure 14: High-Level Notional Enterprise Change and \nInnovation Division\nAssistant Commissioner of Enterprise Change and Innovation will be responsible for integrating \nthe Taxpayer Experience Strategy with other agency priorities and overseeing enterprise level \nprioritization of investments and initiatives. The Assistant Commissioner of Enterprise Change \nand Innovation would also lead signifcant agency change efforts including the organizational \nredesign and implementation of future signifcant legislative changes.\nThe Data Office, led by the Chief Data Officer, will own the development of an enterprise data \nstrategy that will ensure alignment with and ability to support functional unit based strategic \nplans and a long-term strategic vision. This data strategy will also provide the IRS with a \nframework to assess, prioritize, and address data access and analytics needs across the IRS. \nThis office will curate a centralized data management repository, providing an easily accessible \nand accurate source for enterprise-wide decision making. This office will be responsible for \nimplementing the Data Management and Analytics components of the Taxpayer Experience \nStrategy.\n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n114\nInternal Revenue Service \| Taxpayer First Act \n6.6 ENTERPRISE CHANGE AND INNOVATION \n DIVISION\n Ultimately, you \ncannot improve case \nmanagement without improving \nthe digitalization of \npaper records.\n—Jeffrey Tribiano, Deputy Commissioner \nfor Operations Support \nThe Performance Improvement and Change Management Office will advise others across \nthe agency on opportunities to improve internal business processes and reduce duplicative \nactivities in their daily operations. This office will be responsible for developing change \nmanagement and communication strategies across the agency. This group will include Lean Six \nSigma experts who can help improve service to the taxpayer by leading accelerated process \nimprovement initiatives.\nThe Enterprise Digitalization and Case Management \nOffice (EDCMO), which will focus on enhancing the \ntaxpayer experience by improving business processes \nand modernizing systems through two critical initiatives: \nDigitalization and Enterprise Case Management. The \noffice will empower taxpayers and IRS employees to \nresolve issues in a simplifed digital environment. It will \nuse agile customer-centered thinking and draw on leading \nindustry test-and-learn practices to quickly identify what \ncombination of business process and technology works \nbest for the IRS’s customers and employees. \nThe Strategic Planning and Legislative Implementation Office would drive service-wide \nimplementation of the Taxpayer First Act strategies as well as oversee and report on future \nenterprise wide legislation. Additionally, this office would coordinate annual strategic planning \nand prioritization activities working with senior leadership across Relationships and Services, \nCompliance, Operations Management, Information Technology, Taxpayer Advocate Service, \nCounsel, Independent Office of Appeals, Communications, and the Taxpayer Experience Office, \nto enable the IRS to meet our short term and long term strategy goals.\nAdding Value\nCoordinated Strategic Implementation: The IRS is frequently called upon to assist with \nimplementation of legislation. The Enterprise Change and Innovation Division would enable the \nIRS to strategically address legislative changes, standardize execution, enable coordination with \nthe appropriate operating divisions, and securely archive key information. There would also be \na high degree of coordination between the Strategic Planning and Legislative Implementation \nOffice and other strategic offices, including the Taxpayer Experience Office, to ensure service-\nwide alignment of strategic priorities and reporting on the IRS Strategic Plan.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n115\nInternal Revenue Service \| Taxpayer First Act \n6.6 ENTERPRISE CHANGE AND INNOVATION \n DIVISION\nData-Driven Business Decision Making: The Data Office will ensure strategic planning \nbusiness decisions are data driven and in line with documented organizational challenges. \nTo facilitate these business decisions, the Chief Data Officer will collaborate with business \noperations (e.g. Relationships and Services, Compliance) to understand and fulfll their needs. \nThis office will also look to the private sector and identify emerging trends or tools that could \nbe brought into current operations and will play a broader role in using a data-driven approach \nto proactively identify taxpayer insights. Most importantly, this organization will oversee \nimplementation of the Data Management and Analytics component of the Taxpayer Experience \nStrategy, driving the agency toward full data integration and enabling advanced analytics as \nwell as robotics, artifcial intelligence and other innovative solutions that rely on a centralized \nauthoritative data source.\n We need to consider \nthe way we do our \nstrategic planning and \nhow we operationalize \nour strategic plan.\n—Senior Executive IRS Employee\nPromoting Efficiencies / Driving Digitalization \nAccountability Efforts: The Enterprise Digitalization \nand Case Management Office consolidates the \nvarious disparate and fragmented digitalization efforts \nand projects across the agency into one enterprise-\nwide organization. In combination with the Assistant \nCommissioner of Enterprise Change and Innovation, \nthis office will help drive accountability for digitalization \nefforts and capabilities across the IRS which will \nimprove our ability to leverage data to inform our \ncompliance and taxpayer service initiatives.\nEnhanced Innovation: Establishment of the Enterprise Change and Innovation Division as the \n“strategic integrator” would centralize enterprise strategies and initiatives. This centralization \nwould not only drive greater integration, but enable a more holistic approach towards innovation, \nutilizing increased data management, analytics and business process improvement as well as \nleveraging new and evolving industry tools and technologies.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n116\nInternal Revenue Service \| Taxpayer First Act \n6.7 OPERATIONS MANAGEMENT DIVISION\nAs we move forward with implementing our new \norganizational model, we envision a revitalized support \nstructure that will address many of the challenges we \nface in today’s current tax administration environment – \nboth from an external taxpayer delivery perspective and \ninternal operations perspective. In our future organizational \nstructure, the existing Operations Support Division will \nbe partitioned into two distinct divisions: The Information \nTechnology Division, as well as a mission-support focused \nOperations Management Division.\nThe Operations Management Division would consist of \nseveral existing organizational units that are responsible \nfor coordinating and supporting all mission-support \nfunctions for the IRS. Operations Management links \nvarious offices throughout the IRS, ensuring a smooth \nfow of information and ease of internal and workforce \noperations. The Operations Management Division would \ncontain many of the existing support functions within \nOperations Support’s current structure. Operations \nManagement functions would include: Diversity Office, \nHuman Capital Office (HCO), Financial Office, \nFacilities Management and Security Services (FMSS), \nProcurement Office, and Risk Office. These functions \nwould support day-to-day IRS operations, enabling \nother functions within the organization to focus solely on \ntaxpayer service.\nFigure 15: High-level Notional Operations \nManagement Division.\nThe functions within the Operations Management Division would continue to facilitate an \nenvironment of innovation, continuous improvement and operational efficiencies. For example, \nthe Procurement Office has created a contract vehicle for conducting phased, development-\nfocused acquisitions: Pilot IRS. The multi-phased structure used by Pilot IRS allows the Agency \nto quickly issue contract solicitations and experiment with innovative solutions while also \nlimiting risk. This type of innovative approach to solve existing challenges will be amplifed by all \norganizations within the Operations Management Division.\n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n117\nInternal Revenue Service \| Taxpayer First Act \n6.7 OPERATIONS MANAGEMENT DIVISION\nTwo key roles within the Operations Management Division, the Chief Risk Officer and the Chief \nDiversity Officer, would operationally sit within Operations Management but will have a direct \nline to the Commissioner enabling additional oversight, collaboration, and guidance. \nAdding Value\nIncreased Focus on Equity, Diversity and Inclusion: The Diversity Office would operate \nwithin the Operations Management Division, but would also have a dotted-line relationship \ndirectly to the Commissioner. By establishing direct access to the Commissioner, the Diversity \nOffice would be able to easily escalate any diversity or inclusion issues and further the IRS’s \ncommitment to preventing discrimination against employees, customers, and other stakeholders. \nThis relationship will also provide additional opportunities to incorporate equity, diversity, and \ninclusion initiatives with the Agency’s long-term strategies and goals. \nImproved Understanding of Risk: The Risk Office will operate within the Operations \nManagement Division but will also have a dotted-line relationship directly to the Commissioner. \nThis positioning will enable the Commissioner to maintain awareness of outstanding or emerging \nrisks and rapidly develop a mitigation plan or realign resources. This transparency would lead to \nan increased focus on enterprise risks and risk management in both the development of long-\nterm strategies and enterprise-wide decision making. The Risk Office would also collaborate with \nthe Enterprise Change and Innovation Office to effectively manage enterprise risk and inform \nenterprise planning.\nIncreased Focus on Human Capital Initiatives: By reducing the number of offices reporting to \nthe Assistant Commissioner of Operations Management, this structure enables increased focus \nand allocation of resources to the Human Capital Office. The Human Capital Office will work \nwith various offices throughout the organization to reduce redundancies and improve workforce \nplanning and hiring processes. \nAlignment to Strategies / Building Talent: The Operations Management Division will \nenable the Training Strategy by establishing an IRS University (IRSU) within Human Capital, a \ncentralized learning function that leverages technology to provide enhanced training experiences \nfor employees. The Human Capital Office will work with the Information Technology Division to \nsupport the IRS University (IRSU) by identifying requirements, building new capabilities, and \nimplementing new professional development technologies.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n118\nInternal Revenue Service \| Taxpayer First Act \n6.8 INFORMATION TECHNOLOGY DIVISION\nIn our future organizational structure the Information Technology \nDivision would retain current staff, scope, and responsibilities \n(e.g., Strategic Oversight, Enterprise Development, \nCybersecurity, Enterprise Operations/Computing Centers, \nUser and Networks Service, and Enterprise Architecture \nand Engineering, and Program Modernization) in order to \nbetter respond to taxpayer demand for innovative information \ntechnology solutions and online services.\nThe Assistant Commissioner Chief Information Officer \n(ACCIO) would oversee the Information Technology Division \nand will regularly collaborate with the other Commissioner’s \nDirect Reports to understand their technology operational \nrequirements and assist in developing and delivering in \nsupport of enterprise priorities. The Assistant Commissioner \nChief Information Officer would manage the core technology \ninfrastructure and oversee day-to-day IT operations and \ndepartments as well as provide thought leadership on emerging \ntechnologies and select the proper capabilities to integrate into \nthe organization. The Assistant Commissioner Chief Information \nOfficer would work closely with the Procurement Office to \neffectively identify and deploy new capabilities. Additionally, \nthe Assistant Commissioner Chief Information Officer would \nidentify and bring forward key technology related to improving \nthe taxpayer experience and meeting taxpayers’ evolving \nexpectations. The Assistant Commissioner Chief Information \nOfficer would work collaboratively with the Chief Taxpayer \nExperience Officer to ensure alignment with the Taxpayer \nExperience Officer’s efforts to provide the optimal taxpayer \nexperience using innovative technology solutions.\nFigure 16: High-Level Notional Information \nTechnology Division\nThe Assistant Commissioner Chief Information Officer would be responsible for all Agency IT \nservices similar to its current Associate Chief Information Officer areas. To address provision 1302, \nthe Cybersecurity Office would expand its purview to incorporate a more holistic approach of \ncybersecurity activities across the Agency, engaging all operating divisions. This expansion will be \naccomplished through an enhanced and unifed governance framework focusing on strategy and \noperational responses to external and internal threats. This framework will help reduce redundancies \nwhere multiple IRS offices address the same type of cybersecurity issue without collaboration. It \n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n119\nInternal Revenue Service \| Taxpayer First Act \n6.8 INFORMATION TECHNOLOGY DIVISION\nwill also reduce partial identifcation and treatment of cyber incidents, streamline data sharing and \ntreatment and improve Agency-wide oversight of cyber incidents.\nAdding Value\nStreamlining Appropriations: The IRS’s support priorities are more clearly defned, enabling more \nstreamlined funding and appropriations opportunities.\nEarlier Awareness and Increased Collaboration: By aligning the Information Technology functions \nas a direct report to the Commissioner, it drives earlier awareness and increased collaboration with \nthe other members of the Senior Leadership Team and the Commissioner, to address enterprise \npriorities and emerging issues.\nPromoting Cybersecurity Efficiencies / Reducing Fragmentation: The Information Technology \nDivision includes an expanded Cybersecurity Office allowing for an increased collaborative \napproach to plan for cybersecurity activities, improve our ability to respond to cyber threats, reduce \nredundancies in incident response areas, and increase our ability to combat cybersecurity and other \nthreats. This change would also allow for more effective and streamlined recruiting of multi-skilled \ntechnical and relational employees in the cyber space.43 \nContinuity of Operations: In establishing a distinct division for organizations focused on developing \nand implementing technology solutions the Agency would be able to “lift-and-shift” many existing \nfunctions. This would enable select offices to quickly transition to the new model and continue to \nbuild upon key initiatives currently underway. By aligning existing mission-support into two divisions, \nthe structure will enable additional focus on and guidance to the functions and offices within the \nInformation Technology and Operations Management Division. \n43 See Appendix 9.7\n.8 for expanded rationale for how positioning the Cybersecurity office will better position the Agency to \naddress cyber threats.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n120\nInternal Revenue Service \| Taxpayer First Act \n6.9 MEASURING SUCCESS AND ADDITIONAL \n CONSIDERATIONS\nAs we navigate these changes to our organizational structure, it is imperative to evaluate our \neffectiveness and impact to the Agency. We have developed a strategic Organizational Redesign \nMeasures Framework to assess how the recommended changes to the IRS organizational structure \nwill improve our service to taxpayers, enhance the employee experience, and increase operational \nefficiencies within the Agency. Throughout the implementation of the Organizational Redesign \nStrategy, we will use this framework to develop additional, specifc measures to track our progress \nin implementing our Taxpayer First Act priorities. Our future Organizational Blueprint Report will also \nfeature an in-depth analysis on defned performance metrics to gauge implementation progress and \ncomplementary evaluation plan monitoring framework.\nOrganizational Redesign Framework\nThe Organizational Redesign Measures Framework provides us with a guide for developing \nmeasures that consider both internal and external benefts that may result from our \norganizational design change. The framework applies the organizational redesign insights \n(identifed challenges of the organization) and industry best practices as inputs to identify and \ndefne potential measures. Additionally, existing organizational measures can be utilized within \nthe framework to measure redesign success.\nFrom this framework we identifed and developed three primary goals:\n• \nEnhance the taxpayer experience\n• \nEnhance the employee experience \n• \nImprove operational efficiencies\nTwo of the three goals directly align with the Taxpayer Experience Strategy and Training Strategy. \nThe alignment illustrates the strong connection between all three strategies and the need for a \ncomprehensive suite of measures to assess progress in our implementation efforts.\n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n6.9.1 MEASURING SUCCESS\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n121\nInternal Revenue Service \| Taxpayer First Act \n6.9.1 MEASURING SUCCESS\nEnhancing Taxpayer Experience\nOur organizational structure is foundational to the execution of the Taxpayer Experience \nStrategy and enables a responsive approach to changes in future operations. The success of \nthe initiatives within the Taxpayer Experience Strategy is dependent upon an organizational \nstructure that enables us to best serve and interact with taxpayers. The Taxpayer Experience \nStrategic Goal of providing a seamless taxpayer experience can be enhanced by integrating \nprogram areas to create a holistic approach to service delivery. To best capture this alignment, \nthe Organizational Redesign Strategy will use metrics from the Taxpayer Experience Strategy, \nSection 4.2. \nEnhancing Employee Experience\nOur organizational structure must enable our workforce to provide optimal taxpayer service \nand efficient tax administration for compliance of the tax laws. To that end, we will improve our \ntraining, hiring and onboarding processes through our Training Strategy and Human Capital Office \ninitiatives. \nWe will use our annual federal employee surveys to provide periodic long-term assessments of \nthe employee experience and we also plan to use Climate Pulse Surveys to gain quick insight on \nthe general health of our organization as we implement organizational structure changes. We will \nuse this information to assess our improvements on an ongoing basis, quantify the impact of our \nchange management efforts, and identify if we need to revise our initial strategy or refocus our \nefforts.\nFigure 17: Graphic Depicting Org. Redesign Improvement Areas and alignment of notional measures\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n122\nInternal Revenue Service \| Taxpayer First Act \n6.9.1 MEASURING SUCCESS\nThe Office of Personnel Management Federal Employee Viewpoint Survey measures employees’ \nperceptions of whether, and to what extent, conditions characteristic of successful organizations is \npresent in their agencies. The Federal Employee Viewpoint Survey serves as a tool for employees \nto share their perceptions in many critical areas including their work experiences and Agency \nleadership.44 \nImproving Operational Efficiencies\nWe will also focus on capturing operational efficiencies \nrealized as a result of the organizational redesign. Notional \nmeasures for streamlining operations within the agency \nand optimizing resources are provided in Organizational \nRedesign Splash page below, but the specifc measures \nwill be identifed in coordination with development of the \ndetailed Organizational Blueprint Report. We will assess \nopportunities for streamlining functions in both service and \ncompliance operations and operations support functions \nto remove redundant processes, streamlining decision-\nmaking processes through more efficient governance \noptions, and improving communication and collaboration \nacross IRS organizations.\nThe Taxpayer \nFirst Act gives us a \nchance to look at our \nstructure. It gives us a \nchance to look at where \nwe’re effective, efficient, \nand where we can \nstreamline.\n—Lisa Beard, TFAO Executive\n44 Source: Office of Personnel Management Federal Employee Viewpoint Survey.\nIn conjunction with the analysis described to improve the taxpayer experience, we will also \nconduct a comparative analysis of processes, technology use and workforce needs. Utilizing \ncost centers to identify the resource expenditure in our current state and comparing to our future \nimplemented organizational structure resource needs, we can identify where we have made \nprogress in operational efficiencies.\nWhen assessed together, the measures across taxpayer experience, employee experience \nand efficiency gains will provide insight into the progress and success of the organizational \nredesign implementation. Our improvements to the taxpayer experience, employee experience \nand operational efficiencies, will be gradual. Furthermore, the improvements across each of \nthese three areas may vary due to the impact of rapidly implementable short-term initiatives in \ncomparison to large scale enterprise initiatives that may require additional resources up-front \nbefore realizing long-term gains.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n123\nInternal Revenue Service \| Taxpayer First Act \n6.9.1 MEASURING SUCCESS\nThe IRS is a complex and diverse Agency responsible for administering federal tax laws \nthat frequently change. The IRS has also taken on expanded roles in administering social \nprograms that beneft taxpayers, such as a variety of tax credits, Affordable Care Act subsidies \nand Economic Impact Payments. When the Congress creates new laws and programs for the \nIRS to administer, it often does not include additional funding. Our proposed organizational \nstructure is designed to support and enhance the Taxpayer Experience and Training Strategies, \nand we expect improved services and quality of work due to the realignment of the workforce. \nReapplying resources for strategy and innovation and realigning service and enforcement \nfunctions will provide better revenue protection and allows us to be more agile in the approach \nwe use to administer our very diverse programs and responsibilities. Cost saving opportunities \nfrom removing duplicative processes will be identifed with development of the Organizational \nBlueprint Report, but the major beneft of the reorganization is optimizing the effects of the \nTaxpayer Experience Strategy and empowering our employees to do their job in the most \neffective manner.\nIt takes a suite of measures across multiple impact categories to assess progress of our \nTaxpayer First Act strategies and organizational change. We will monitor the measures \nthroughout implementation and modify, as necessary.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n124\nInternal Revenue Service \| Taxpayer First Act \n6.9.2 \nNON-STRUCTURAL COMPONENTS \nCRITICAL TO SUCCESS\nAppropriations\nSuccessful implementation of the strategies called for by the TFA require changes to the IRS fnancial \nstructure to ensure IRS appropriations refect the new organizational structure. The IRS proposes to \nrevise its fnancial structure to follow private sector business principles and align support costs to the \nprograms they support. \nThe proposed IRS Centralized Services Fund would link support costs directly to mission activities. The \nCongress would appropriate funding for all activities within the same appropriation as the program they \nsupport. Thus the “consumer” of those resources would have a fnancial incentive to use these support \nservices more strategically and efficiently. \nAdditional information on Appropriations recommendations are described in Section 9.8. \nIn addition to the organizational structural changes and proposed adjustments to appropriations, the \nAgency will also need to make changes in the following areas:\nPolicy and Legislation: Policy and legislative changes are needed to improve IRS efficiency, enhance \ntaxpayer rights, and improve the taxpayer experience. See Section 9.7\n.9 for additional details. \nWorking Relationships with our Oversight and Advisory Partners: More proactive engagement \nwith oversight partners and greater coordination managing engagement with oversight and advisory \nentities is needed to streamline our processes.\nWhen you look at major compliance issues, \nthese issues can’t be addressed \nin one year… we need to come up with a \nplan and proposal for a 2-3 year budget so \nthat we can focus on these issues in a 2-3 \nyear timeline.\n \n —Senior Executive IRS Employee\nGovernance Structure and Processes\nStreamlining governance structures and \nprocesses will provide more efficient decision-\nmaking, greater accountability for actions, and \nreduction in duplicative efforts.\nThese areas are critical to establishing a \nsuccessful environment for the agency to \nmaximize the effectiveness of our organizational \nchanges and implement on our taxpayer \nexperience goals. Details on these recommended \nchanges are outlined in Section 9.7\n.11\n.\n6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n125\nInternal Revenue Service \| Taxpayer First Act \nEnhance the \ntaxpayer experience\nEnhance the \nemployee experience\nImprove operational \nefﬁciencies\nTIMELINE\nGOALS\nORGANIZATIONAL REDESIGN STRATEGY\nThe Organizational Redesign Strategy will \nbe implemented in phases that are closely \naligned with the implementation of the Taxpayer \nExperience Strategy and Training Strategy.\nComplete realignment of organizational design \nis highly dependent upon annual budget \ncommitments. Continued ongoing investments \nwill be needed to successfully reorganize at all \nlevels across the organization.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n126\nInternal Revenue Service \| Taxpayer First Act \nOrganizational Redesign Timeline and Measures\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n127\nInternal Revenue Service \| Taxpayer First Act \nOrganizational Redesign Timeline and Measures\nGOAL\nOBJECTIVE\nNOTIONAL MEASURE\nEnhance the \nTaxpayer Experience\nEvaluate access to an \nIRS Assistor\n when needed\nEnterprise Level of Service\nEvaluate IRS ability to \nprovide a \nfrictionless experience\nA-11 Survey Question: I am satisfed with the service I received from the IRS\nEvaluate progress on \nmeeting future resource \nrequirements to enable \nthe Taxpayer\n Experience Strategy\nKey performance indicators of the workforce (e.g., vacancy counts, percentage of \nworkforce demonstrating critical skill sets)\nEnhance the \nEmployee Experience\nEvaluate employee \nunderstanding and \nexpertise on compliance \nactivities and processes\nEmployee Survey Response (e.g., When something unexpected comes up in your \nwork do you usually know who to ask for help? Can you see a clear link between your \nwork and your functional unit’s goals and objectives?)\nEvaluate trust and \nrespect of senior \nleaders\nFEVS (e.g., My organization’s senior leaders maintain high standards of honesty and \nintegrity. Managers communicate the goals of the organization.)\nImprove Operational \nEfficiencies\nStreamline the structure \nof the \nmodernized Agency\nDecrease in number of duplicative services and responsibilities within the Agency\nOptimize use of \nresources for critical \nprograms executing the \ncore components of \ntaxpayer service\nCost savings or reinvestment opportunities generated by the elimination or \nconsolidation of duplicative processes (e.g., use select pilots, based on redesign \ninsights (challenges of current organization), comparing resource needs through \nestablished cost centers for current state versus future state of organization)\n", "128\nInternal Revenue Service \| Taxpayer First Act \n7.0 \| KEY CONSIDERATIONS\nS E C T I O N7\nInternal Revenue Service \| Taxpayer First Act \nKEY\nCONSIDERATIONS\nInternal Revenue Service \| Taxpayer First Act \n", "To implement the Taxpayer Experience, Training and Organizational Redesign Strategies, the \nIRS must create a sustainable plan, along with a program office to ensure accountability and to \nmonitor and guide the successful transformation of the IRS.\nSince the passage of the TFA in July 2019, the TFAO has served as the coordination point \nfor the Act’s 45 provisions. The IRS will continue to operate a program office - the Strategic \nPlanning and Legislative Implementation Office45 - to provide clear ownership, implementation \nand transition of the strategies. This office will ensure timely and effective implementation, \ncontinually assess organizational priorities, consider legislative impacts and evaluate emerging \ntechnologies. Office responsibilities will include: \n•\nDeveloping program-level implementation timeline and schedule.\n•\nProducing detailed plans for the future IRS organizational structure.\n•\nCoordinating an agency-wide implementation roadmap of the Taxpayer Experience Strategy.\n•\nCoordinating with the Human Capital Office on implementation of the Training Strategy.46\n•\nExecuting the Change Management and Communication plans outlined in subsections 7\n.2 and\n7\n.3.\n•\nTracking TFA related measures and metrics outlined in Sections 4.2, 5.6 and 6.9.1\n.\nImplementing these strategies is an Agency-wide effort, which will be coordinated by the \nStrategic Planning and Legislative Implementation Office. The following sections address the \nkey implementation activities required to transform the IRS and achieve the goals of our TFA \nstrategies. These activities include:\n•\nInternal Revenue Manual (IRM) Guidance\n•\nChange Management\n•\nCommunications\n•\nResource Considerations\nThe IRS will continuously re-evaluate and update the strategies and implementation plans. \nUpdates will be based on funding, changes in legislative mandates or other factors that may \nrequire adjustment of IRS organizational priorities in the future.\n129\nInternal Revenue Service \| Taxpayer First Act \n7.0 KEY CONSIDERATIONS\n1\n2\n9\nInternal Revenue Service \| Taxpayer First Act \n45Described in Section 6.6.\n46The Human Capital Office will maintain overall responsibility for the Training Strategy.\n7.0 \| KEY CONSIDERATIONS\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n130\nInternal Revenue Service \| Taxpayer First Act \n7.0 \| KEY CONSIDERATIONS\n130\nInternal Revenue Service \| Taxpayer First Act\n7.1 INTERNAL REVENUE MANUAL GUIDANCE\nClear guidance to IRS employees is required to implement the strategies discussed in this \nreport. The IRS’s Internal Revenue Manual (IRM) is the official source of IRS policies and \nprocedures and the means for communicating them to our workforce, taxpayers, and other key \nstakeholders. IRS program owners are responsible for developing, publishing and updating \nprocedures in the IRM related to administering their programs. Each section of the IRM must be \naccurate, clear and current to ensure the fair and equitable treatment of taxpayers.\nThe sweeping nature of the changes envisioned in the TFA strategies will require a signifcant \nrewrite of the IRM to a scope and scale not seen in 20 years. Required updates to the IRM \nbased on the Taxpayer Experience and Training Strategies will be incorporated incrementally \nover time as the capabilities and procedures are fully developed by program owners, procedural \ncontent associated with the TFA capabilities is written by IRM authors, negotiated with NTEU, \nand published formally in the IRM. This effort of updating the IRM based on the Taxpayer \nExperience and Training Strategies will be completed over a multi-year timeframe. \nTo accomplish this vast and complex task, we will convene Agency-wide, multi-functional teams \nof IRM authors and subject matter experts. \nAs IRM Sections are updated based on the TFA capabilities and priorities, the IRS will provide \nappropriate training to impacted employees. The IRS Organizational Redesign plan will require \nupdates to some IRM Sections. Implementation of the IRS Organizational Redesign will follow \na different timeline than the Taxpayer Experience and Training Strategies, and identifcation of \nimpacted IRM Sections will be initiated in FY2022. \nStakeholders inside and outside the Agency shared that the clarity and consistency of the IRM \nhas a direct impact on the taxpayer experience and needs improvement. Creating a clearer and \nmore organized IRM will require a signifcant investment by the IRS. We will explore ways to \nmore quickly and effectively update IRM content based, in part, on the continuous feedback loop \nenvisioned in the Taxpayer Experience Strategy. This enhanced process will keep our employees \nmore informed and better equipped to assist taxpayers. The value of this investment will result \nin swifter issue resolution, time saved for taxpayers and our employees and an improvement in \ntaxpayer satisfaction. Additional information on IRM guidance can be found in Appendix 9.6.5.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n131\nInternal Revenue Service \| Taxpayer First Act \n131\nInternal Revenue Service \| Taxpayer First Act\n7.2 CHANGE MANAGEMENT\nThe results and outcomes \nof workplace changes are \nintrinsically and inextricably \ntied to individual employees \ndoing their jobs differently.\n— Change Management: The People \nSide of Change by Jeffery M Hiatt \nand Timothy J Creasey\nThrough the IRS’s continuous journey to improve the taxpayer experience and enhance internal \noperations, the organization has transformed in many ways over the years. Changes have been \ndriven by both external and internal factors including; new legislation, technological advances, \nincreased partnerships with stakeholders, realignments and reorganizations, resources and \nstaffing, and other process improvement efforts. Today, the agency is poised to transform \nitself once again, re-thinking how we deliver services, and how taxpayers and stakeholders \nexperience tax administration.\nOrganizational Culture and Supporting Change\nChange in any organization occurs in the context of the organization’s culture. Change at the IRS \nmust factor in the different sub-cultures that have developed in more than 20 distinct operating \ndivisions. These range in size from small, specialized programs to large divisions serving \ndifferent taxpayer segments, stakeholders and employees. The existence of many overlapping \nsub-organizations creates special challenges in driving the enterprise change needed to create \na new, overarching organizational culture.\nThe Organizational Change Management (OCM) \nprogram will provide tools to help teams assess the \nculture and identify changes needed in mindset and \nattitudes. Since 2017\n, the IRS has been intentional \nabout building an infrastructure to support change \ninitiatives. The OCM program was established to \naccelerate the IRS’s transformation efforts by advising \nchange leaders and integrating principles of employee \nchange into strategic initiatives. Linking to strategic \ninitiatives enables the OCM to support efforts to \nmitigate the risk of failure and positively affect employee \nmorale and program effectiveness. \n7.0 \| KEY CONSIDERATIONS\nCurrently, more than 90 employees in 21 different IRS \norganizations are trained change practitioners who \nwill be deployed to support change in their business \nunits. These individuals will partner with teams for \nspecifc initiatives, bringing a change management discipline to support employees in driving \nthe sweeping organizational changes envisioned in our Taxpayer Experience, Training and \nOrganizational Redesign strategies. \n", "132\nInternal Revenue Service \| Taxpayer First Act \n5.0 \| TRAINING STRATEGY\n132\nInternal Revenue Service \| Taxpayer First Act \n7.2 CHANGE MANAGEMENT\nWe need to build \na better sense of community \nwithin the IRS – one IRS.\n— IRS Employee\nStrategies for Leading Change Within the Organization\nTo achieve the vision outlined in this report, IRS employees must embrace a new way of \napproaching their jobs. A transformed IRS will bring changes in technology, processes and \nstructure. Employees will experience these changes in different ways depending on where \nthey work within the organization, but the scope of the changes will affect the entire workforce. \nEffective change management is essential for the IRS to successfully implement these \nstrategies.\nLeading change will begin with active and visible IRS executive sponsorship. IRS leadership will \ndevelop communications that are consistent and create an understanding of, and support for, the \nimplemented changes. While our communications strategy is critical to driving change, it is one \npiece in a larger framework focused on mobilizing employees to achieve the desired outcomes \nof these strategies. Successfully implementing the TFA strategies will also require commitment \nfrom IRS leaders and employees to embrace, adopt and execute change. The IRS will ensure \nagency-wide communication strategies anticipate and address employee questions.\n7.0 \| KEY CONSIDERATIONS\nOur communication will be informed by best \npractices in leading and managing change. We \nwill focus on ensuring employees understand why \nchange is taking place, what is expected from \nthem, how their work might be affected and what \nnew skills they will need to develop. Messages \nwill be tailored to the diverse audiences in each \noperating division to address their specifc \nquestions and concerns.\nChanging culture takes time and requires incremental changes to structure and processes. The \nIRS strategy for change management will defne the specifc behavioral changes that can drive \npositive change in culture. \nIn the long-term, these efforts will foster a culture that embraces the vision of a taxpayer \nfocus, instills change leadership capabilities and proactively engages employees on change \ninitiatives. Leaders will support employees through change management. The active and visible \nengagement of employees will result in an improved world-class taxpayer experience.\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n133\nInternal Revenue Service \| Taxpayer First Act \n133\nInternal Revenue Service \| Taxpayer First Act\n7.3 COMMUNICATIONS PLAN\nAlong with the stand-up of the TFAO, a strategic communication plan was established to engage \nemployees, taxpayers, tax professionals and other stakeholders about the TFA legislation in \na two-way dialogue. The plan included the creation of both internal and external electronic \nmailboxes to receive recommendations and feedback; and was also supported by extensive \noutreach efforts. The PVUSFBDI efforts aligned with the TFAO Guiding Principles: Listen, Learn \nand then Design, built excitement through regular and transparent communications. \nGoing forward, we will maintain the electronic mailboxes, continue diverse outreach efforts \nwith employees, taxpayers, and stakeholders. Will maintain communications with our oversight \npartners and NTEU as we implement the strategies outlined in this report. \nWe will continue to expand our community and industry stakeholder partnerships to better inform \nour partners and engage unique taxpayer groups like those with limited English profciency and \ntraditionally underserved populations. We will also leverage our social media channels. \nSuccessful business improvements are driven by collaborative efforts of project management, \ncommunication strategies and change management practices. The Communications Plan \nemphasized a need for close collaboration between the TFAO and the IRS Office of \nChange Management.\n7.0 \| KEY CONSIDERATIONS\n", "6.0 \| ORGANIZATIONAL REDESIGN STRATEGY\n134\nInternal Revenue Service \| Taxpayer First Act \n134\nInternal Revenue Service \| Taxpayer First Act \n7.4 RESOURCE CONSIDERATIONS\nFor each strategy and operating division-owned provision, we have developed costing estimates \nthat will support the future vision of the IRS while also building upon existing efforts. The costs \nassociated with the TFA were segmented into high-level categories and various phases outlined \nin this report: \nTaxpayer Experience Strategy: Costed over a period of fve years and broken out into the \nphases required by Section 1101 in the TFA. This strategy builds upon existing IRS efforts \nto improve the taxpayer experience and levels of service the IRS provides.\nTraining Strategy: Costed over a period of fve years and broken out into phases to \nsupport the Taxpayer Experience Strategy, including costs reviewed by the Information \nTechnology organization. \nOrganizational Redesign Strategy: Costed over a period of fve years, beginning in \nFY2021 but may be subject to modifcations dependent upon our detailed implementation \nplan. \nTaxpayer First Act Office: Costs refect the creation and implementation of the above \nstrategies, management of the Operating Division Provisions and drafting of this report. \nOperating Division Provisions: Refers to 10 of the remaining 42 provisions assigned to \nspecifc operating divisions and IT with implementation dates effective immediately through \nFY2023. These costs started accruing with the passage of the Taxpayer First Act in FY2019 \nand continue through FY2022, but to date, no funds have been appropriated for these \nprovisions.\nThese estimates were developed with the Chief Financial Officer and respective stakeholders. \nAdditional details and the methodology for each category are included in Appendix 9.5. \n7.0 \| KEY CONSIDERATIONS\n", "135\nInternal Revenue Service \| Taxpayer First Act \n135\nInternal Revenue Service \| Taxpayer First Act \n7.0 \| KEY CONSIDERATIONS\n7.4 RESOURCE CONSIDERATIONS\nAssumptions\n• \nAcceleration of Delivery: Efforts during the early years of these strategies will lay the \ngroundwork and build upon each other to accelerate the deployment of capabilities in the \nout-years, creating signifcant improvements to the taxpayer experience. \n• \nYear 0: No funds were appropriated for FY2020 to cover costs incurred to develop these \nstrategies or implement specifc provisions. In FY2020 the IRS spent $67\n.5 million on the \nimplementation of the legislatively mandated provisions. The $67\n.5 million spent on the \nlegislatively mandated Operating Division Provisions are included in the total TFA costs, \noutlined in Table 1, for FY2021-FY2025. \n• \nYears 1 – 5: These cost estimates are provided in the aggregate and subject to further \nrefnement when incorporated into more detailed implementation plans.\nDependencies\nThe TFA builds upon the investments and deliveries of the IRS Integrated Modernization Plan.47 \nThe remaining four years of this six-year modernization plan of IT systems requires an additional \nestimated investment of $1.9 billion. This plan identifes the critical infrastructure needed for the \nimplementation of by the Taxpayer First Act capabilities. Our ability to deliver on the Taxpayer \nFirst Act strategies defned in this report depends on critically needed multi-year Congressional \ninvestment in IRS resources. \n47 Internal Revenue Service Integrated Modernization Business Plan, Publication 5336, April 2019.\n", "136\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n7.4 RESOURCE CONSIDERATIONS\nTaxpayer First Act\nThousands of Dollars\nTFA Cost\nEstimates\nFY2020 Actual Costs \nFY2020 Legislatively Mandated Provisions (e.g., Establishment of IRS Independent Office of Appeals, \nIdentity protection personal identifcation numbers, Management of IT Information, Internet platform for Form \n1099 flings, Disclosure of taxpayer information for third-party income verifcation, Uniform standards for the \nuse of electronic signatures, Mandatory e-fling by exempt organizations, 3rd Party Authentication for On-Line \nAccess)\n$67\n,476\nFY2021 - FY2025 Estimated Costs\nTaxpayer Experience Strategy\n$1,227\n,000\nExpanded Digital Services (e.g., Secure 2-Way Messaging, Taxpayer View History, Change Account \nInformation, Digital Notifcations, Business Online Account, Tax Professional Online Account, Expand \nPayment Options, Secure Document Exchange)\n$337\n,000\nSeamless Experience (e.g., Expand Automated Callback, Wait Time Transparency, Concierge Navigation \nSupport, 360 Degree View of T\naxpayer Account by Employee, AI Powered Informational Web Chat/Digital \nAppointments/Employee Assistant)\n$378,000\nProactive Outreach and Education (e.g., Personalized T\nax Updates, Social Media Strategy, Simplify and \nImprove Notices and Correspondence, Plain Language Communications)\n$149,000\nCommunity of Partners (e.g., Build and Expand T\nrusted Stakeholder Network, Leverage Community \nOutreach Best Practices, Co-Located Government Services, Expand Community Presence, Data Sharing \nOpportunities)\n$68,000\nFocused Strategies for Reaching Underserved Communities (e.g., T\nranslate Forms/Publications/Notices, \nDigitally Aided T\nranslation and Interpretation, Recruitment, Leverage Employee Multilingual Skills, Translation \nApp, International Online Account, Focused Promotion of IRS eFile, Virtual Face-to-Face, Virtual Discussion \nForums)\n$54,000\nEnterprise Data Management and Advanced Analytics (e.g., Automated Feedback Loop, Comprehensive \nData Repository, Advanced Analytics, Data Sharing Opportunities)\n$241,000\nTraining Strategy (e.g., IRS University, T\naxpayer-First T\nraining, Continuous Learning for All Employees, Utilizing \nTechnology)\n $123,000 \nOrganizational Redesign Plan/ TFAO Operations (e.g., Org Structure Design and Refne, Transition and \nImplement, Change Management and Communications)\n$216,000\nLegislatively Mandated Provisions (e.g., Establishment of IRS Independent Office of Appeals, Identity \nprotection personal identifcation numbers, Management of IT Information, Internet platform for Form 1099 \nflings, Disclosure of taxpayer information for third-party income verifcation, Uniform standards for the use of \nelectronic signatures, Mandatory e-fling by exempt organizations, 3rd Party Authentication for On-Line Access)\n$550,000\nFY2021 - FY2025 Taxpayer First Act Costs\n$2,116,000\nTotal Taxpayer First Act Costs\n$2,183,000\n7.0 \| KEY CONSIDERATIONS\nT\nable 1: High-level summary of the costs associated with the T\naxpayer First Act \n \n", "1.0 \| COMMISSIONER’S WELCOME\n1\n3\n7\nInternal Revenue Service \| Taxpayer First Act \n8.0 \| IRS: NEXT STEPS\nInternal Revenue Service \| Taxpayer First Act\n8.0 \nIRS: NEXT STEPS\nThe Taxpayer First Act empowers the IRS to be aspirational on behalf of our taxpayers. Taxpayers \ndeserve an IRS that provides top quality service, assists them with timely responses to their \nquestions, has the ability to promptly resolve their account issues and to help them more easily \nnavigate and understand their tax obligations. To put it simply, America needs a fully functioning and \nwell-resourced revenue Agency. \nThe COVID-19 pandemic reminded us all how quickly the world can change. Despite signifcant \noperational and workforce disruptions, IRS employees proudly rose to the challenge to support our \nnation and help distribute the largest economic relief packages in history to our fellow Americans. \nWith the implementation of the strategies detailed in this report, the Agency will be better positioned \nto respond to future crises. We have a strong history of delivering for the nation’s taxpayers and our \nfuture efforts will be no different. With additional resources, we will transform the IRS into a modern, \nefficient and taxpayer-centered organization.\nThe future vision of the IRS will bring changes in technology, processes and structure. Employees will \nexperience positive changes in different ways depending on where they work within the organization, \nbut the scope of the changes will affect the entire workforce. We commit to providing employees with \nconsistent messaging from all levels of leadership about what is changing and why, emphasizing \ntheir critical role in the continued success of the organization. We will continue to collaborate across \nthe Agency to strategically and tactically align on new initiatives. As we move forward with our future \nstrategic planning efforts, our Taxpayer First Act strategies will be our guide.\nThe bedrock of our Organizational Redesign Strategy will be built upon our 5'\"0 Guiding Principles \nand, a willingness to hear and seek GFFECBDL from employees and the National Treasury Employees \nUnion. Together, we will define the IRS of the future. We envision dedicating FY2021 to developing \nan Organizational Blueprint Report which will provide a comprehensive update on reorganization \nimplementation activities, progress and associated timelines. This Organizational Blueprint Report \nwill also feature an in-depth analysis on costs, measures, implementation plans and project risks. \nWith appropriate funding, we will also begin implementing the initiatives outlined in the Training \nStrategy and the Taxpayer Experience Strategy.\n137\n", "1.0 \| COMMISSIONER’S WELCOME\n1\n3\n8\nInternal Revenue Service \| Taxpayer First Act \n8.0 \| IRS: NEXT STEPS\n138\nInternal Revenue Service \| Taxpayer First Act\nWe will employ a consolidated, integrated and coordinated program management and governance \napproach to oversee the implementation of the TFA Strategies, IRS Strategic Plan and future \nlegislative mandates. This approach will include monitoring progress towards achieving milestones \nand delivering strategic initiatives on time as well as the discipline of managing project plans/\nschedules and risks; monitoring quality controls; documenting critical decisions and streamlining \ngovernance. Our actions will yield efficiencies with respect to tracking progress towards milestones \nacross multiple Service-wide initiatives. Our Program Management Office will monitor and assess \nprogress of identified measures and reevaluate the effectiveness of the reorganization.\nWhile we are thankful to the Congress on the passage of the TFA legislation and the opportunities it \nprovides the IRS to change, we remain reliant on the Congress to support funding such an \nendeavor. Employees, taxpayers, tax professionals and many others across our entire tax \ncommunity contributed immeasurably to this report and they, like us, are relying on this report turning \ninto action. With the implementation of our strategies we will positively impact our community and we \nwill continue to pursue our critical mission on behalf of our country and every American.\nIRS Commissioner and Deputy Commissioners\nCharles Rettig, Commissioner\nSunita Lough, Deputy Commissioner for Services and Enforcement\nJeffery T\nribiano, Deputy Commissioner for Operations Support\nTFAO Leadership\nLia Colbert, \nTaxpayer First Act Office Lead\nLisa Beard, \nTaxpayer First Act Executive\nJames Clifford, \nTaxpayer First Act Executive\nRobert Ragano, \nTaxpayer First Act Executive\nIRS Senior Executive Team\n+VTUJO\u0001\"CPME\u000e-B#SFDIF,\u0001%JSFDUPS,\u0001&OUFSQSJTF\u0001$BTF\u0001.BOBHFNFOU\u0001BOE\u0001$P\u000e%JSFDUPS,\u0001\n%JHJUBMJ[BUJPO\u0001BOE\u0001$BTF\u0001.BOBHFNFOU\nRobin D. Bailey, Jr., IRS Human Capital Officer\nThomas Brandt, Chief Risk Officer\nCarol Campbell, Director Return Preparer Office\nRobert Choi, Chief Privacy Officer\nErin M. Collins, National Taxpayer Advocate\nKenneth Corbin, Commissioner, Wage and Investment Division\nMichael Desmond, Chief Counsel\nElizabeth Dugger, \nAssistant Deputy Commissioner for Operations Support\nSharyn Fisk, Director, Office of Professional Responsibility\nValerie Gunter, Chief Diversity Officer\nKaren Howard, Director, Office of Online Services\n", "1.0 \| COMMISSIONER’S WELCOME\n1\n3\n9\nInternal Revenue Service \| Taxpayer First Act \n8.0 \| IRS: NEXT STEPS\n139\nInternal Revenue Service \| Taxpayer First Act\n5FSFTB\u0001)VOUFS,\u0001$IJFG\u0001'JOBODJBM\u00010GGJDFS\nEric Hylton, Commissioner, Small Business/Self-Employed Division\nBarry Johnson, \nActing Chief Research and Analytics Officer\nAndrew Keyso, Chief IRS Independent Office of Appeals\nEdward T\n. Killen, \nActing CommissJoner, \nTax Exempt and Government Entities Division\u0001\nJames Lee, Chief Criminal Investigation\nTerry Lemons, Chief Communications and Liaison\nLee Martin, Director Whistleblower Office\nKevin McIver, Chief of Staff\nDouglas O’ Donnell, Commissioner, Large Business and International Division \u0001\nRichard Rodriguez, Chief, Facilities Management and Security Services\nNancy Sieger, \nActing Chief Information Officer\n)BSSJTPO\u00014NJUI,\u0001%JSFDUPS,\u0001%JHJUBMJ[BUJPO\u0001BOE\u0001$P\u000e%JSFDUPS,\u0001&OUFSQSJTF\u0001%JHJUBMJ[BUJPO\u0001\nBOE\u0001$BTF\u0001.BOBHFNFOU\nShanna Webbers, Chief Procurement Officer\n", "140\nInternal Revenue Service \| Taxpayer First Act\n140\nInternal Revenue Service \| Taxpayer First Act\n140\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\nAPPENDIX\nS E C T I O N9\n", "9.0 \| APPENDIX\n141\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n141\n141\n141\n9.1 METHODOLOGY \n OVERVIEW\nThe Methodology Overview outlines the timeline and process for establishing the Taxpayer First \nAct Office. This section will also discuss how the TFAO conducted research and information \ngathering to create and refne the three Taxpayer First Act Strategies. \n9.1.1 ESTABLISHING THE \n TAXPAYER FIRST ACT OFFICE\nImmediately after the Taxpayer First Act (TFA) was codifed, the IRS Commissioner, Charles \n(Chuck) Rettig, established an executive team to launch and lead the TFA Office (TFAO). \nThe TFAO took primary responsibility for implementing specifc TFA provisions including 1) \nthe Comprehensive Taxpayer Experience Strategy (TFA §1101), 2) the Modernization of IRS \nOrganizational Structure (TFA §1302), and 3) the Comprehensive Training Strategy (TFA \n§2402). The TFAO was also charged with leading the integration, communications, program \nmanagement, and governance activities for the remaining 42 provisions owned by different \noperating divisions across the IRS. \n9.1.2 RESEARCH AND INFORMATION \n GATHERING \nThe Research and Information Gathering Phase included engaging internal and external \nstakeholders and analyzing their feedback and pertinent documents to develop the strategies. \nWe then socialized and reviewed the solidifed strategies, cleared the report with oversight \norganizations and submitted the report to the Congress.\nInternal Revenue Service \| Taxpayer First Act \n", "9.0 \| APPENDIX\n142\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n142\n142\n142\n9.1.2.1 EXTERNAL STAKEHOLDERS\nExternal stakeholders included taxpayers, partners, advisory groups, industry groups, oversight \norganizations and other government agencies. The TFAO used a vigorous outreach strategy \nto ensure we gathered feedback that encompassed the unique needs and expectations of \nall taxpayer segments. As part of this effort, we engaged wage earners and self-employed \nindividuals, small and large businesses, international businesses and individuals, and tax-\nexempt and government entities through town halls, focus groups, interviews and/or forums. \nWe held over 140 different external stakeholder engagement activities. At each event, we shared \nthe [email protected] mailbox to obtain additional stakeholder feedback. We received 182 emails \nwith suggestions from external stakeholders. The mailbox remains open to continue engaging \nwith stakeholders. \n \nThe TFAO sponsored a series of Taxpayer First Act Stakeholder Forums in January 2020 and \nJuly 2020 and invited a diverse cross section of external stakeholder groups. We used the \nForums to engage in a conversation with stakeholders and encouraged them to provide input on \nthe development of the TFA strategies. These forums included tax accounting frms representing \nsmall and large businesses, professional/trade groups, payroll industry groups, Low Income Tax \nClinics and state, foreign, and tax-exempt representative groups. \n9.1.2.2 INTERNAL STAKEHOLDERS \nInternally, we engaged employees, management and senior executives from all levels of \nthe organization and from across the country. We held over 30 different internal stakeholder \nengagement activities including site visits, townhall meetings, and focus groups (see Appendix \n9.4 for more details). We collected more than 630 pieces of employee feedback from over \n100 articles posted on our intranet. We created the Innovation Advisory Council (IAC), which \nprovided a bi-weekly forum for senior executives and the TFAO to discuss TFA deliverables. \nAdditionally, the TFAO hosted bi-weekly meetings with senior leaders and representatives from \neach IRS function. These discussions were key to ensuring alignment across all provisions while \nproviding another venue to collect input for developing the comprehensive Taxpayer Experience \nStrategy, Training Strategy and Organizational Redesign Strategy. \n", "9.0 \| APPENDIX\n143\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n143\n143\n143\n9.1.2.3 ANALYZE AND DEVELOP\nFollowing the Research and Information Gathering phase, the Analyze and Develop phase \ninvolved distilling information from thousands of pages of feedback and research into key \ninsights, opportunities and enablers. These key insights formed the foundation to developing the \nstrategies outlined in this Report.\n9.1.2.4 INCORPORATE FEEDBACK\nThe Taxpayer Experience, Training, and Organizational Redesign Strategies went through \nsignifcant rounds of feedback and review during the drafting process. The Taxpayer Experience \nand Training Strategies were reviewed for comment by representatives from each operating \ndivision across the IRS. Leadership from every operating division participated in this review \nprocess. The Taxpayer Experience, Training, and Organizational Redesign Strategies were \nsocialized and reviewed with the IRS Senior Leadership Team in a series of IAC meetings, \nwhere leadership provided direct feedback during hours of discussions. In addition, a group \nof IRS executive leaders from across the IRS reviewed all three strategies and participated \nin disposition sessions with the TFAO team to provide targeted comments and feedback. In \naddition to these internal methods for capturing feedback, the strategies were also shared with \nexternal partners, such as the Assistant Secretary of the Treasury for Management, the TFA \nForums, tax practitioners via National Public Liaison (NPL) and the Electronic Tax Administration \nAdvisory Committee (ETAAC), individual taxpayers via the Taxpayer Advocacy Panel or surveys, \nand many more. Given the IRS’s reach and complexity, it was a priority to hear from our diverse \npool of internal and external stakeholders before moving forward with strategy development. \n9.1.2.5 SOCIALIZE, REVIEW AND PLAN\nOur strategies were broadly socialized with internal IRS audiences using internal \ncommunications such as IRS Headline articles, TFAO IRS Source intranet pages and various \nbriefngs tailored for an array of employee audiences. Our strategies were also socialized \nexternally with partners such as the American Bankers Association and NPL, via forums like the \nIRS Nationwide Tax Forums or ad hoc presentations.\n", "9.0 \| APPENDIX\n144\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n144\nInternal Revenue Service \| Taxpayer First Act \nInternal Revenue Service \| Taxpayer First Act \n144\n144\n144\n9.2 STRATEGIC ALIGNMENT\nOnce complete, the TFAO cross-walked the TFA strategies with existing IRS strategic initiatives, \nincluding the IRS Strategic Plan FY2018-FY2022, the IRS Integrated Modernization Business \nPlan and the IRS’ response to the 21st Century Integrated Digital Experience Act (IDEA). We \ndetermined there was a high degree of alignment with existing strategic approaches. Where we \nidentifed potential gaps between TFA and the existing IRS initiatives we coordinated with IRS \nleadership to understand and mitigate these strategic gaps. We also relied on measures and \nmetrics from the FY2019 Key Insights Report, which builds on the IRS Mod Plan and the IRS \nStrategic Plan FY2018-FY2022, including a comprehensive performance and year-end budget \nsummary. \nWe see an opportunity to align the Agency’s strategic direction and priorities for taxpayer-facing \ninitiatives and planning through the Taxpayer Experience Strategy. This strategy was developed \nin full consideration of a multitude of other strategies and planning documents. As a result, \nthe Agency can now look to the Taxpayer Experience Strategy as the overarching, prevailing \nstrategic document to drive prioritization of investments and strategic direction going forward.\n", "9.0 \| APPENDIX\n145\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n145\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n145\n145\n145\n9.3 STATUS OF THE 42 \n OPERATING DIVISION \n PROVISIONS\nThe TFAO took primary responsibility for the three TFA provisions addressed in this report:\n•\nComprehensive Taxpayer Experience Strategy (TFA §1101)\n•\nComprehensive Training Strategy (TFA §2402)\n•\nModernization of IRS Organizational Structure (TFA §1302)\nIn addition to developing these three strategies, the TFAO coordinated with offices across the \nIRS to oversee the implementation of the other 42 provisions of the Act. Table 9.3.1 explains \nhow we measured the status of the 42 Operating Division provisions of the TFA. Table 9.3.2 \nsummarizes each of these provisions and their status.\n", "9.0 \| APPENDIX\n146\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n146\n146\n146\nThe COVID-19 pandemic has delayed the implementation of some of these provisions, including \nthis report. The delivery of the following provisions were impacted: \n•\nOn April 17th, 2020, the IRS notifed The Senate Finance and House Ways and Means\nCommittees the following provisions, planned for delivery in July 2020 would need to be\ndelayed until December of that same year.\n•\nSection 1101 – Comprehensive Taxpayer Experience Strategy\n•\nSection 2402 – Comprehensive Training Strategy\n•\nSection 1302 – Modernization of IRS Organizational Structure\n•\nAs of December 2020, the IRS was on track to timely implement the vast majority of TFA\nprovisions. Nonetheless, disruptions due to the COVID-19 pandemic or other constraints\nhave posed challenges for fully implementing the following TFA provisions by the statutory\ndue dates noted below in parentheses. We will continue to work on these provisions to\nensure their complete implementation.\n•\nSection 1205, which prohibits the IRS from using private collection agencies\nto recover delinquent taxes from individuals whose income is substantially all\nsupplemental security income benefts or disability insurance beneft payments\nor individuals whose adjusted gross income is below 200% of the poverty level.\n(Original delivery date: December 31, 2020).\n•\nSection 2008, which requires the IRS to develop and implement case management\nguidelines to reduce taxpayer burden for stolen identity refund fraud cases within one\nyear of enactment of the TFA (Original delivery date: July 1, 2020).\n•\nSection 2302, which requires the IRS to publish guidance establishing uniform\nstandards and procedures for accepting electronic signatures for disclosure and\nother authorizations for practitioners within six months of enactment of the TFA\n(Original delivery date: January 1, 2020).\n•\nSection 2304, which requires the IRS to authenticate users of electronic services\naccounts beginning 180 days after the date of enactment of the TFA (Original\ndelivery date: January 1, 2020).\n", "9.0 \| APPENDIX\n147\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n147\n147\n147\nTABLE 9.3.1 EXECUTIVE SUMMARY OF STATUS OF \nTHE 42 OPERATING DIVISION \nPROVISIONS (AS OF DECEMBER 2020)\nProvision Status\nStatus Description\nProvision Count\nProvision Met\nThe minimum requirements of the provisions have been \nmet as required by law. The Business Unit/BOD Provision \nOwner has stated the following:\n1) TFA codifying activities were completed or already in\nplace: and/or\n2) Activities such as interim IRM updates, interim\nguidance, communications, employee training, manual\nprocess, IT minimal viable product (MVP) are in place.\n(a) Follow-on activities (e.g., ﬁnal IRM updates, ﬁnal\nguidance, follow-on communications, full IT solution or \nenhancements, etc.) are documented in the TDA EIPP \nand LATIS.\n31\nOn Schedule\nAll activities that are critical for the implementation of all \nthe provisions are on track for completion by the effec-\ntive date.\n6\nAt Risk\nOne or more activity that is critical for the \nimplementation of the provisions may not be complete \nby the effective date.\n0\nLate\nOne or more activity that is critical for the implementa-\ntion of the provision is late/past the effective date.\n4\nNot Applicable\nProvision no longer applies to the Taxpayer First Act\n1\nTABLE 9.4.2 INTERNAL OUTREACH ACTIVITIES\nTotal\n42 Provisions\n", "9.0 \| APPENDIX\n148\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n148\n148\n148\nTABLE 9.3.2 STATUS OF THE 42 OPERATING \nDIVISION PROVISIONS\nProvision \nNumber\nProvision Name\nLegislation Date Due\nOverall Status\n1001\nEstablishment of Internal Revenue Service \nIndependent Ofﬁce of Appeals\n7/1/2020\nProvision Met\n1102\nLow-income exception for payments \notherwise required in connection with a \nsubmission of an offer-in-compromise\n7/1/2019\nProvision Met\n1201\nInternal Revenue Service seizure \nrequirements with respect to transactions\n7/1/2019\nProvision Met\n1202\nExclusion of interest received in action to \nrecover property seized by the Internal \nRevenue Service based on structuring \ntransaction\n7/1/2019\nProvision Met\n1203\nClariﬁcation of equitable relief from joint \nliability\n7/1/2019\nProvision Met\n1204\nModiﬁcation of procedures for issuance of \nthird-party summons\n8/15/2019\nProvision Met\n1205\nPrivate debt collection and special \ncompliance personnel program\n12/31/2020\nLate*\n1206\nReform of notice of contact of third parties\n8/15/2019\nProvision Met\n1207\nModiﬁcation of authority to issue designated \nsummons\n8/15/2019\nProvision Met\n Disruptions due to the COVID-19 pandemic or other constraints have posed challenges for\nfully implementing certain TFA provisions by the statutory due dates. Additional information will\nbe shared upon request.\n*The original legislation as written and provided on July 2019 with the passing of the TFA did\nnot account for 1205 Section “a” (Certain Tax Receivables Not Eligible for Collection Under Tax\nCollection Contracts). This required the IRS to submit a technical correction to be incorporated\nin new or revised legislation for SSA to share the required Supplemental Security Income (SSI)\ndata with IRS. A technical correction was submitted to the Senate Finance and House Ways\nand Means Committees in April 2020, to allow for this data exchange.\n", "9.0 \| APPENDIX\n149\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n149\n149\n149\n1208\nLimitation on access of non-Internal \nRevenue Service employees to returns and \nreturn information\n7/1/2019\nProvision Met\n1301\nOfﬁce of the National Taxpayer Advocate\n7/1/2019\nProvision Met\n1401\nReturn preparation programs for applicable \ntaxpayers\n7/1/2019\nProvision Met\n1402\nProvision of information regarding low-\nincome taxpayer clinics\n7/1/2019\nProvision Met\n1403\nNotice from IRS regarding closure of \ntaxpayer assistance centers\n7/1/2019\nProvision Met\n1404\nRules for seizure and sale of perishable \ngoods restricted to only perishable goods\n7/1/2020\n Provision Met\n1405\nWhistleblower reforms\n7/1/2019\nProvision Met\n1406\nCustomer service information\n7/1/2019\nProvision Met\n1407\nMisdirected tax refund deposits\n1/1/2020\nProvision Met\n2001\nPublic-private partnership to address identity \ntheft refund fraud\n7/1/2019\nProvision Met\n2002\nRecommendations of Electronic Tax \nAdministration Advisory Committee (ETAAC) \nregarding identity theft refund fraud\n7/1/2019\nProvision Met\n2003\nInformation sharing and analysis center\n7/1/2019\nProvision Met\n2004\nCompliance by contractors with \nconﬁdentiality safeguards\n1/1/2023\nOn Schedule\n2005\nIdentity protection personal identiﬁcation \nnumbers\n7/1/2024\nOn Schedule\n2006\nSingle point of contact for tax-related \nidentity theft victims\n7/1/2019\nProvision Met\n2007\nNotiﬁcation of suspected identity theft\n1/1/2020\nProvision Met\n2008\nGuidelines for stolen identity refund fraud \ncases\n7/1/2020\nLate\n2009\nIncreased penalty for improper disclosure or \nuse of information by preparers of returns\n7/1/2019\nProvision Met\n2101\nManagement of Internal Revenue Service \ninformation technology\n7/1/2020\nProvision Met\n2102\nInternet platform for Form 1099 ﬁlings\n1/1/2023\nOn Schedule\n2103\nStreamlined critical pay authority for \ninformation technology positions\n7/1/2019\nProvision Met\n", "9.0 \| APPENDIX\n150\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n150\n150\n150\n2201\nDisclosure of taxpayer information for third-\nparty income veriﬁcation\n1/1/2023\nOn Schedule\n2202\nLimit redisclosures and uses of consent-\nbased disclosures of tax return information\n1/1/2020\nProvision Met\n2301\nElectronic ﬁling of returns\n7/1/2019\n(12/31/2019, \n12/13/2020, \n12/31/2021)\nOn Schedule\n2302\nUniform standards for the use of electronic \nsignatures for disclosure authorizations to, \nand other authorizations of, practitioners\n1/1/2020\nLate\n2303\nPayment of taxes by debit and credit cards\n7/1/2019\nProvision Met\n2304\nAuthentication of users of electronic services \naccounts\n1/1/2020\nLate\n2401\nRepeal of provision regarding certain tax \ncompliance procedures and reports\n7/1/2019\nProvision Met\n3001\nProhibition on rehiring any employee of the \nInternal Revenue Service who was involun-\ntarily separated from service for misconduct\n7/1/2019\nProvision Met\n3002\nNotiﬁcation of unauthorized inspection or \ndisclosure of returns and return information\n1/1/2020\nProvision Met\n3101\nMandatory e-ﬁling by exempt organizations\n1/1/2021\n1/1/2022\nOn Schedule\n3\u001202\nNotice required before revocation of tax-\nexempt status for failure to file return\n6/1/2020\nProvision Met\n3201\nIncrease in penalty for failure to ﬁle\n1/1/2020\nNot Applicable \n", "9.0 \| APPENDIX\n151\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n151\n151\n151\n9.4 COMMUNICATIONS AND \n OUTREACH \nTABLE 9.4.1 INTERNAL COMMUNICATIONS \n VEHICLES\nInternal \nCommunication \nVehicles\nPublish/\nCompletion \nDate\nBusiness Operating \nDivision\nTitle/Subject\nAlert\n9/18/2019\nSmall Business / Self \nEmployed (SB/SE)\nTaxpayer First Act signed into law\nBusiness \nOperating Division \nIntranet\n10/24/2019\nLarge Business & \nInternational (LB&I)\nMandated changes to the IRS’s Third Party Contact \nprocedures\n10/28/2019\nWage & Investment \n(W&I)\nHelp Shape Our Future\n11/18/2019\nTax Exempt & \nGovernment Entities \n(TE/GE)\nReview of the New Third Party Contact Procedures \nmandated by the Taxpayer First Act\n11/25/2019\nW&I\nField Assistance strives to deliver state-of-the-art \nservice at Taxpayer Assistance Centers\n11/22/2019\nSB/SE\nTFA SB/SE Headline News\n11/26/2019\nInformation \nTechnology (IT)\nThe Go-Getters Guide to the Taxpayer First Act\n1/21/2020\nW&I\nCustomer Callback expands in W&I and SB/SE\n6/8/2020\nW&I\nDesign Ofﬁce employees deliver bold look to TFA Lab\n8/31/2020\nW&I\nW&I employees share feedback for the future IRS\nBubbler\n10/21/2019\nHuman Capital Ofﬁce \n(HCO)\nHCO 2022 effort will help ensure we have the \nresources we need to accomplish our mission\n", "9.0 \| APPENDIX\n152\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n152\n152\n152\nBusiness Unit \nNews (BUN)\n1/13/2020\nW&I\nExplore new possibilities at W&I’s Taxpayer First Act \nwebsite\n2/25/2020\nSB/SE\nSB/SE answers call for feedback on TFA provisions \n3/19/2020\nIT\nTeam looks to refresh and update the IT Strategic Plan\n3/31/2020\nChief Financial Ofﬁcer \n(CFO)\nLearn about new budget guidance on TFA and \nEnterprise Case Management\n4/15/2020\nCFO\nMake sure you understand the new budget guidance \non TFA and Enterprise Case Management\n6/1/2020\nCommunications & \nLiaison (C&L)\nCommunity of Partners\n6/24/2020\nC&L\nTFA Overview presentation\n7/20/2020\nC&L\nTFA Update\nBusiness Unit \nWeb Content\n7/2/2019\nSB/SE\nLegislative Update 2019-1: Detailed Summary of \nP.L.116-25 (H.R. 3151), Taxpayer First Act\n7/26/2019\nSB/SE\nInterim Guidance on Third-Party Contact Notiﬁcation \nProcedures\n8/16/2019\nSB/SE\nThird Party Contacts – Collection\n8/19//2019\nSB/SE\nThird Party Contacts: Campus (ACS Letters \nTemporarily Suspended)\n8/20/2019\nSB/SE\nThird Party Contacts: Campus (ACS LT40 Temporarily \nSuspended)\n8/30/2019\nSB/SE\nThird Party Contacts: Letter 3164\n9/6/2019\nSB/SE\nThird Party Contacts – Examination\n9/20/2019\nSB/SE\nChanges made to third party contacts notice \nprocedures\n10/1/2019\nSB/SE\nThird Party Contact Procedures - Update\n11/19/2019\nSB/SE\nSB/SE Today - Posted Commissioner’s message to \nemployees requesting feedback on TFA implementation\n2/18/2020\nSB/SE\nSB/SE Today - Posted Commissioner’s message: SB/\nSE answers call for feedback on TFA provisions\n3/13/2020\nSB/SE\nIRS increases penalty for improper disclosure \nconnected to identity theft\n3/13/2020\nSB/SE\nTaxpayer First Act restates how IRS responds to \nstructuring and seizures\n8/18/2020\nSB/SE\nSB/SE Today - Posted Commissioner’s message: Learn \nthe latest about the Taxpayer First Act\n", "9.0 \| APPENDIX\n153\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n153\n153\n153\nCommissioners’ \nNews\n2/24/2020\nC&L\nTaxpayer First Act Innovation Lab opens in D.C.\nEquity Diversity & \nInclusion (EDI) \nInsider\n10/30/2019\nEquity, Diversity & \nInclusion (EDI)\nTFA insert - November EDI Insider\n2/3/2020\nEDI\nTFA – February EDI Insider\n3/10/2020\nEDI\nTFA – March EDI Insider\nEmail- All \nEmployees\n10/9/2019\nLB&I\nTaxpayer First Act Ofﬁce seeks big-picture input from \nLB&I\n10/21/2019\nLB&I\nTaxpayer First Act: We want to hear from you\n11/6/2019\nW&I\nTFA: Exploring new possibilities as One IRS\n11/13/2019\nSB/SE\nSB/SE Commissioner’s monthly message\n12/9/2019\nLB&I\nWatch or listen to short video to learn more about the \nTaxpayer First Act\n1/16/2020\nLB&I\nLB&I Commissioner and Deputy Commissioner \nmonthly message\n1/21/2020\nLB&I\nTaxpayer First Act implements changes dealing with \nsummonses\n4/6/2020\nLB&I\nShare your perspective soon on how technology can \nimprove the IRS\n4/27/2020\nLB&I\nTaxpayer First Act status update\n6/1/2020\nLB&I\nTaxpayer First Act update: IRS expands critical help to \ntaxpayers\n6/15/2020\nLB&I\nTaxpayer First Act implements changes dealing with \nsummonses\n7/27/2020\nLB&I\nNew resources provide the latest on Taxpayer First Act \ndevelopments\n7/30/2020\nLB&I\nLB&I Commissioner and Deputy Commissioner \nmonthly message\n8/18/2020\nSB/SE\nI SB/SE Commissioner Message: Learn the latest \nabout the Taxpayer First Act\n9/8/2020\nLB&I\nT Watch new Taxpayer First Act video then share your \nfeedback about ways to improve the IRS\n10/8/2020\nSB/SE\nSB/SE FY2021 Focus Guide- It’s STILL the time!\n10/13/2020\nLB&I\nTaxpayer First Act: Share your ideas on how we can \nbetter serve taxpayers with different abilities\n", "9.0 \| APPENDIX\n154\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n154\n154\n154\nEmail-All \nManagers\n8/12/2019\nSB/SE\nThird Party Contacts New Procedures Exam-Field \nManagers PPT\n10/15/2019\nLB&I\nThe Taxpayer First Act Ofﬁce wants to hear from LB&I\n10/15/2019\nReturn Preparer \nOfﬁce (RPO)\nTaxpayer First Act Info\n10/21/2019\nLB&I\nTaxpayer First Act: We want to hear from you\n11/8/2019\nW&I\nTFA: Exploring new possibilities as One IRS\n11/13/2019\nSB/SE\nSB/SE Commissioner’s message\n12/9/2019\nLB&I\nWatch or listen to short video to learn more about the \nTaxpayer First Act\n2/3/2020\nLB&I\nTaxpayer First Act status and resources\n6/15/2020\nLB&I\nTap into Taxpayer First Act resources\n7/20/2020\nLB&I\nTap into newly available resources for updates on \nTaxpayer First Act\n8/4/2020\nHCO\nBoost your digital leadership with the 2020 Managers’ \nContinuing Professional Education (CPE) program\n9/8/2020\nLB&I\nTaxpayer First Act update: Four key insights and \nopportunities lead to six \"Big Ideas\"\n10/13/2020\nLB&I\nTaxpayer First Act: Share your ideas on how we can \nbetter serve taxpayers with different abilities\nEmail-Speciﬁc \nOfﬁces\n11/19/2019\nRPO\nTFA - What you need to know\n11/26/2019\nIT\nIT Communications: Update on Taxpayer First Act\n2/7/2020\nRPO\nTaxpayer First Act - Latest News\n2/18/2020\nSB/SE\nSB/SE answers call for feedback on TFA provisions \n2/26/2020\nC&L\nTaxpayer First Act pop-up session\n2/27/2020\nC&L\nTFA Input Sharing: Senior Executive Team \n6/15/2020\nRPO\nTaxpayer First Act Update\n6/23/2020\nC&L\nSenior Executive Team email: TFA update and \noverview \nEmail-Targeted \nEmployees\n1/27/2020\nC&L\nInnovation lab kick-off ceremony email\n3/2/2020\nC&L\nInnovation lab reminder email\n3/16/2020\nC&L\nInnovation lab closure email\n7/1/2020\nIT\nA Year-in-Review: Supporting the Taxpayer First Act\n10/1/2020\nAppeals\nTaxpayer First Act Training for Appeals employees\n10/8/2020\nAppeals\nTaxpayer First Act Training for Appeals employees\nEmail-Targeted \nManagers\n10/17/2019\nIT\nIT Communications: Update on Taxpayer First Act\n", "9.0 \| APPENDIX\n155\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n155\n155\n155\nIn the Know (IT)\n10/1/2019\nIT\nFour Things to Know about the Taxpayer First Act\n11/26/2019\nIT\nThe Go-Getters Guide to the Taxpayer First Act\n2/4/2020\nIT\nIt’s never too late to provide feedback to the TFA Ofﬁce\n3/17/2020\nIT\nTeam looks to refresh and update the IT Strategic Plan\n7/7/2020\nIT\nIT has played a key role implementing Taxpayer First \nAct provisions across the Service\n7/21/2020\nIT\nTap into newly available resources for updates on \nTaxpayer First Act\n8/4/2020\nIT\nBoost your digital leadership with the 2020 Managers’ \nContinuing Professional Education (CPE) program\n8/18/2020\nIT\nTaxpayer First Act update: Four key insights and \nopportunities lead to six \"Big Ideas\"\n9/01/2020\nIT\nTaxpayer First Act: Share your ideas on how we can \nbetter serve taxpayers with different abilities\n9/15/2020\nIT\nTFA - What you need to know\n10/13/2020\nIT\nIT Communications: Update on Taxpayer First Act\nIRS Headlines\n10/15/2019\nC&L\nTaxpayer First Act - Latest News\n11/4/2019\nC&L\nSB/SE answers call for feedback on TFA provisions \n11/25/2019\nC&L\nTaxpayer First Act pop-up session\n11/25/2019\nC&L\nTFA Input Sharing: Senior Executive Team \n1/6/2020\nC&L\nTaxpayer First Act Update\n1/13/2020\nC&L\nSenior Executive Team email: TFA update and \noverview \n1/20/2020\nC&L\nInnovation lab kick-off ceremony email\n1/27/2020\nC&L\nInnovation lab reminder email\n2/3/2020\nC&L\nInnovation lab closure email\n2/10/2020\nC&L\nA Year-in-Review: Supporting the Taxpayer First Act\n2/18/2020\nC&L\nTaxpayer First Act Training for Appeals employees\n3/2/2020\nC&L\nTaxpayer First Act Training for Appeals employees\n3/9/2020\nC&L\nIT Communications: Update on Taxpayer First Act\n3/16/2020\nC&L\nFour Things to Know about the Taxpayer First Act\n3/16/2020\nC&L\nThe Go-Getters Guide to the Taxpayer First Act\n3/25/2020\nC&L\nIt’s never too late to provide feedback to the TFA Ofﬁce\n3/30/2020\nC&L\nTeam looks to refresh and update the IT Strategic Plan\n", "9.0 \| APPENDIX\n156\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n156\n156\n156\nIRS Headlines\n4/2/2020\nC&L\nIT has played a key role implementing Taxpayer First \nAct provisions across the Service\n5/27/2020\nC&L\nIRS expands critical taxpayer assistance through \nCommunity of Partners\n7/6/2020\nTaxpayer Advocate \nService (TAS)\nNational Taxpayer Advocate Erin Collins delivers her \nﬁrst report to the Congress; identiﬁes COVID-19 \nchallenges, CARES Act, and Taxpayer First Act \nimplementation as priority issues for taxpayers\n7/20/2020\nCFO\nWe’ve reached the half-way point of our Strategic Plan\n7/20/2020\nC&L\nCheck out the Taxpayer First Act Update\n8/17/2020\nC&L\nTake 12: Taxpayer First Act overview in twelve minutes\n8/28/2020\nC&L\nTaxpayer Experience “We Heard You” video\n9/30/2020\nC&L\nCase management milestone: New foundational and \nbusiness capabilities delivered in TE/GE FY2020 partial \nrelease\n9/30/2020\nC&L\nCase management milestone: New foundational and \nbusiness capabilities delivered in TE/GE FY2020 partial \nrelease\nIRS Source\n10/8/2019\nC&L\nTFA Website Launch\n12/16/2019\nC&L\nInternal Social Media\n1/9/2020\nC&L\nInternal Social Media\n1/14/2020\nC&L\nInternal Social Media\n1/21/2020\nC&L\nInternal Social Media\n1/28/2020\nC&L\nInternal Social Media\n2/3/2020\nC&L\nInnovation lab reminder email\n2/4/2020\nC&L\nInternal Social Media\n2/11/2020\nC&L\nInternal Social Media\n2/18/2020\nC&L\nInternal Social Media\n2/18/2020\nC&L\nTFA in Action: Stakeholder Liaison outreach\n2/25/2020\nC&L\nInternal Social Media\n3/3/2020\nC&L\nInternal Social Media\n3/10/2020\nC&L\nInternal Social Media\n3/17/2020\nC&L\nInternal Social Media\n3/24/2020\nC&L\nInternal Social Media\n3/31/2020\nC&L\nInternal Social Media\n4/7/2020\nC&L\nInternal Social Media\n4/10/2020\nC&L\nTaxpayer Advocate Service\n4/14/2020\nC&L\nInternal Social Media\n4/21/2020\nC&L\nInternal Social Media\n", "9.0 \| APPENDIX\n157\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n157\n157\n157\nIRS Source\n4/27/2020\nC&L\nW&I completed provisions 1406 and 2007\n4/28/2020\nC&L\nInternal Social Media\n5/5/2020\nC&L\nInternal Social Media\n5/12/2020\nTaxpayer Advocate \nService (TAS)\nInternal Social Media\n5/19/2020\nCFO\nInternal Social Media\n5/26/2020\nC&L\nInternal Social Media\n6/2/2020\nC&L\nInternal Social Media\n6/9/2020\nC&L\nInternal Social Media\n6/16/2020\nC&L\nInternal Social Media\n6/16/2020\nC&L\nTFA Overview presentation – iManage\n6/19/2020\nC&L\nTFA Overview presentation article\n6/23/2020\nC&L\nInternal Social Media\n6/30/2020\nC&L\nInternal Social Media\n7/7/2020\nC&L\nInternal Social Media\n7/14/2020\nC&L\nTFA Video: “We Heard You”\n7/14/2020\nC&L\nInternal Social Media\n7/21/2020\nC&L\nInternal Social Media\n7/28/2020\nC&L\nInternal Social Media\n8/3/2020\nC&L\nInternal Social Media\n8/10/2020\nC&L\nInternal Social Media\n8/17/2020\nC&L\nInternal Social Media\n8/21/2020\nC&L\nInternal Social Media\n8/31/2020\nC&L\nInternal Social Media\n9/7/2020\nC&L\nInternal Social Media\n9/14/2020\nC&L\nInternal Social Media\n9/21/2020\nC&L\nInternal Social Media\n9/28/2020\nC&L\nInternal Social Media\n10/5/2020\nC&L\nInternal Social Media\n10/13/2020\nC&L\nInternal Social Media\nLeader’s Alert\n10/8/2019\nC&L\nTaxpayer First Act Manager Toolkit is now available on \niManage\n3/17/2020\nC&L\nTools available to share feedback overview\n3/24/2020\nCFO\nMake sure your employees know about new budget \nguidance on TFA and Enterprise Case Management\n7/14/2020\nC&L\nTFA Update Package\n8/11/2020\nC&L\nAdd the Taxpayer First Act Overview videos to your staff \nmeetings\n9/10/2020\nHCO\nLeaders’ Alert: New interim guidance on rehiring \nformer employees with prior misconduct issues\n", "9.0 \| APPENDIX\n158\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n158\n158\n158\nNewsletter\n7/11/2019\nAppeals\nTaxpayer First Act\n11/6/2019\nW&I\nTFA: Exploring new possibilities as One IRS\n12/5/2019\nAppeals\nReminder: Volunteers for Taxpayer First Act - \nRedaction Initiative\n12/20/2019\nRPO\nRPO Quarterly Newsletter - TFA Article\n1/6/2020\nW&I\nTFAO holds townhall with Brookhaven employees\n1/16/2020\nW&I\nSpreading the word on the W&I TFA survey at the \ncampus\n1/17/2020\nW&I\nDeputy Commissioner for Services and Enforcement \nSunita Lough visits Fresno\n2/3/2020\nW&I\nTFAO visits Ogden campus\n4/3/2020\nAppeals\nGet ready for the Taxpayer First Act Appeals Technical \nEmployee training \n4/17/2020\nAppeals\nGet ready for the Taxpayer First Act Appeals Technical \nEmployee training \n7/30/2020\nAppeals\nComing in the fall: Taxpayer First Act training\n8/6/2020\nAppeals\nHow do I name scanned ﬁles for Taxpayer First Act?\n8/20/2020\nAppeals\nComing soon: Taxpayer Digital Communications secure \nmessaging\n9/17/2020\nAppeals\nTaxpayer First Act training for Appeals\n9/30/2020\nLB&I\nIRS history in the making: The Taxpayer First Act and \nYou\n10/8/2020\nAppeals\nTaxpayer First Act training for Appeals\nPGLD 24/7\n8/20/2020\nPrivacy, \nGovernment \nLiaison & \nDisclosure \n(PGLD)\nThe IRS Style Guide has been updated for e-signature\n8/20/2020\nPGLD\nPGLD 24x7: Taxpayer First Act: We Heard You video\n9/17/2020\nPGLD\nPrivacy, Governmental Liaison and Disclosure\ncompletes provision 3002 of the Taxpayer First Act\nReader Poll\n10/30/2019\nC&L\nWhat wide-ranging piece of IRS tax legislation includes \nprovisions designed to improve taxpayer service and \nensure the IRS continues to enforce tax law in a fair\n1/6/2020\nC&L\nThe Taxpayer First Act Section 1206 changed the Notice \nof Contact of Third Parties to require the IRS to:\n1/9/2020\nC&L\nWhat notiﬁcation process did Taxpayer First Act Section \n1405 affect? \n", "9.0 \| APPENDIX\n159\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n159\n159\n159\nReader Poll\n3/16/2020\nC&L\nThe Taxpayer First Act Section 1403 now requires \nWage and Investment Field Assistance to provide public \nnotiﬁcation of Taxpayer Assistance Center closures:\n5/26/2020\nC&L\nTFAO gathered employee input on taxpayer experience...\n6/4/2020\nC&L\nWhich external stakeholder did not share feedback?\n7/7/2020\nC&L\nWhich business unit submitted over 40 TFA placemat \nresponses?\n8/5/2020\nC&L\nHow many provisions are part of TFA?\n9/11/2020\nC&L\nWhich idea is part of the TFA Taxpayer Experience \nStrategy’s Six Big Ideas?\n10/1/2020\nC&L\nHave you heard of the Enterprise Digitalization and Case \nManagement Ofﬁce?\n10/13/2020\nC&L\nWhat are some of the proposed capabilities that could \nimprove the taxpayer experience?\nSB/SE Executive \nMessage\n11/13/2019\nSB/SE\nSB/SE Executive TFA Commissioner’s e-mail\nSB/SE Headline \nNews\n7/12/2019\nSB/SE\nNew law includes provisions to improve service, \nenforcement, modernization\n9/30/2019\nSB/SE\nChanges to OIC Low-Income Application Fee Process – \nCollection (10/20/2019)\n11/15/2019\nSB/SE\nSB/SE Commissioner message\n11/22/2019\nSB/SE\nNow is the time for SB/SE to shape its future \n1/24/2020\nSB/SE\nImplementation of the Tax Cuts and Jobs Act of 2017 \nand Taxpayer First Act of 2019 provisions\n2/21/2020\nSB/SE\nSB/SE answers call for feedback on TFA provisions\n3/13/2020\nSB/SE\nArticles highlight provisions of Taxpayer First Act: \nTaxpayer First Act restates how IRS responds to \nstructuring and seizures; IRS increases penalty for \nimproper disclosure connected to identity theft \n7/24/2020\nSB/SE\nCheck out the Taxpayer First Act Update\n8/21/2020\nSB/SE\nSB/SE Commissioner message\n10/01/2020\nSB/SE\nPenalty Increase - Improper Disclosure Connected to \nIdentity Theft\nSET Message\n1/27/2020\nC&L\nInnovation lab kick-off email to SET\nWebbie\n9/2/2020\nC&L\nTake six: Taxpayer Experience “Big Ideas” in six minutes\n", "9.0 \| APPENDIX\n160\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n160\n160\n160\nTABLE 9.4.2 INTERNAL OUTREACH ACTIVITIES\nInternal \nCommunication \nVehicles\nPublish/\nCompletion \nDate\nBusiness Operating \nDivision\nTitle/Subject\nConference Call\n11/18/2019\nResearch, Applied \nAnalytics & Statistics \n(RAAS)\nRAAS Manager TFA Feedback Session\n12/3/2019\nRAAS\nRAAS Employee TFA Feedback Session 1\n12/4/2019\nRAAS\nRAAS Employee TFA Feedback Session 2\n12/11/2019\nW&I \nW&I Executive TFA Overview\n2/26/2020\nTFAO\nIRS Employee Organizations\n3/4/2020\nTFAO\nNextGen\n3/10/2020\nTFAO\nStrategic Planning (CFO) Community of Practice\n3/16/2020\nTFAO\nSenior Commissioner Representative Annual Executive \nMeeting \n3/17/2020\nTFAO\nRefundable Credits Program Management \n3/19/2020\nTFAO\nTFA Overview draft for SB/SE Business Support Ofﬁce\n3/23/2020\nTFAO\nResearch Director’s Coordinating Council Meeting\n3/25/2020\nTFAO\nIT User & Network Services\n4/15/2020\nTFAO\nProfessional Managers Association/Formal Managers \nAssociation \n5/1/2020\nTFAO\nNational Taxpayer Advocate / Taxpayer Advocate \nService\n5/5/2020\nTFAO\nW&I Accounts Management\n5/5/2020\nTFAO\nInternal Management Document Community Virtual \nConference\n5/14/2020\nTFAO\nFiling Season Readiness Executive Steering Committee \n5/19/2020\nTFAO\nStrategic Planning (CFO) Community of Practice\n6/10/2020\nTFAO\nLB&I Cross Border Activities Sr Mgrs and Executives.\n6/23/2020\nTFAO\nSB/SE Business Support Ofﬁce Session\n6/26/2020\nTFAO\nNational Treasury Employees Union (NTEU)\n", "9.0 \| APPENDIX\n161\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n161\n161\n161\nConference Call\n8/17/2020\nTFAO\nChief Counsel Continuing Professional Education\n8/24/2020\nC&L\nCommunications & Liaison Stakeholder Liaison \nleadership update\n8/26/2020\nIT\nWeb Apps Executive Oversight Team \n9/22/2020\nTFAO\nSB/SE HCO Leadership Meeting\n9/23/2020\nTFAO\nTransformation Project Management Ofﬁce (TPMO) \nStrategic Planning Workshop \nExecutive Ofﬁce \nStrategy Sessions\n11/14/2019\nIT\nIT Executive Offsite\nLeadership \nMeetings\n10/18/2019\nTFAO\nInnovation Advisory Council\n10/25/2019\nTFAO\nInnovation Advisory Council\n11/1/2019\nTFAO\nInnovation Advisory Council\n11/15/2019\nTFAO\nInnovation Advisory Council\n12/6/2019\nTFAO\nInnovation Advisory Council\n12/13/2019\nTFAO\nInnovation Advisory Council\n1/24/2020\nTFAO\nInnovation Advisory Council\n2/7/2020\nTFAO\nInnovation Advisory Council\n2/21/2020\nTFAO\nInnovation Advisory Council\n3/6/2020\nTFAO\nInnovation Advisory Council \n5/15/2020\nTFAO\nInnovation Advisory Council\n5/29/2020\nTFAO\nInnovation Advisory Council\n6/5/2020\nTFAO\nInnovation Advisory Council \n6/12/2020\nTFAO\nInnovation Advisory Council\n6/26/2020\nTFAO\nInnovation Advisory Council\n7/31/2020\nTFAO\nInnovation Advisory Council\n8/28/2020\nTFAO\nInnovation Advisory Council\n9/3/2020\nTFAO\nInnovation Advisory Council \n9/11/2020\nTFAO\nInnovation Advisory Council \nTalking Points\n9/26/2019\nTFAO\nLocal Taxpayer Advocate Listening Session\n10/10/2019\nC&L\nIRS Leadership Update: Executives\n10/15/2019\nC&L\nIRS Leadership Update: Managers\n10/16/2019\nC&L\nIRS Leadership Update: Managers\n1/30/2020\nC&L\nInnovation lab Commissioner talking points\n", "9.0 \| APPENDIX\n162\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n162\n162\n162\nTown Hall\n10/2/2019\nIT\nCIO Town Hall\n10/7/2019\nIT\nCIO Town Hall\n10/7/2019\nLB&I\nLB&I all-managers town hall\n10/8/2019\nIT\nChief Information Ofﬁcer (CIO) Town Hall\n10/10/2019\nLB&I\nLB&I quarterly all-employees town hall\n10/21/2019\nC&L\nSB/SE Leadership Town Hall\n10/28/2019\nTFAO\nManager Listening Session: Philadelphia Campus\n10/30/2019\nTFAO\nManager Listening Session: Philadelphia Green Federal \nOfﬁce Building\n11/6/2019\nIT\nCIO Town Hall\n11/12/2019\nTFAO\nOgden Site Visit\n11/19/2019\nTFAO\nBrookhaven & NYC Site Visit\n12/3/2019\nTFAO\nFresno, Los Angeles, Glendale and El Monte Site Visits\n12/10/2019\nIT\nCIO Town Hall\n12/12/2019\nTFAO\nTaxpayer Assistance Center (TAC) Visit - Atlanta\n12/19/2019\nTFAO\nInterviews/Work Observations with RAs and ROs\n1/8/2020\nTFAO\nStakeholder Partnership, Education & Communication \n(SPEC) /TAC Manager Listening Session\n1/31/2020\nTFAO\nBaltimore Accounts Management Call Site Session \n2/5/2020\nLB&I\nQuarterly LB&I all-managers town hall\n2/6/2020\nLB&I\nQuarterly LB&I all-employees town hall\n3/4/2020\nTFAO\nNew Carrollton Federal Building Pop-Up session\n5/18/2020\nLB&I\nLB&I Town Hall \n5/20/2020\nPGLD\nIRS Privacy Council \n5/21/2020\nLB&I\nLB&I Town hall\n6/25/2020\nTFAO\nChange Management Community of Practice Town Hall \n8/13/2020\nRPO\nReturn Preparer Ofﬁce Virtual Town Hall\n8/17/2020\nLB&I\nLB&I All-Employee Town Hall (August 17 & 18)\n", "9.0 \| APPENDIX\n163\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n163\n163\n163\nDIAGRAM 9.4.3 INTERNAL COMMUNICATIONS \n AND OUTREACH \n ACTIVITIES ANALYSIS \n", "9.0 \| APPENDIX\n164\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n164\n164\n164\nTABLE 9.4.4 EXTERNAL \n COMMUNICATION VEHICLES\nInternal \nCommunication \nVehicles\nPublish/\nCompletion \nDate\nBusiness Operating \nDivision\nTitle/Subject\nCongressional \nUpdate\n8/1/2019\nC&L\nWhistleblower reforms under the Taxpayer First Act\n11/18/2019\nTFAO\nInfo for Congressional Staff - Taxpayer First Act\n12/2/2019\nC&L\nWe want your feedback\n1/6/2020\nC&L\nWe want your feedback\ne-News for Payroll \nProfessionals\n11/22/2019\nC&L\nIRS launches Taxpayer First Act webpage, email\ne-News for Small \nBusiness\n11/27/2019\nC&L\nIRS launches Taxpayer First Act webpage, email\ne-News for Tax \nProfessionals\n11/22/2019\nC&L\nIRS launches Taxpayer First Act webpage, email\n1/3/2020\nC&L\nRecent legislation requires tax-exempt orgs to eFile \nforms\nFact Sheet\n7/20/2020\nC&L\nTaxpayer First Act Taxpayer Experience Strategy\n7/20/2020\nC&L\nTaxpayer First Act Training Strategy\n7/20/2020\nC&L\nTaxpayer First Act Organizational Redesign Strategy\nInstagram @\nIRSNews\n12/31/2019\nC&L\nTFAO mailbox promo\nIRS Video Portal\n11/20/2019\nC&L\nTaxpayer First Act Introductory Video \n1/14/2020\nC&L\nTax Talk Today: TFA online series of educational \nprograms for practitioners\n7/21/2020\nC&L\nTaxpayer First Act Overview\n7/21/2020\nC&L\nTaxpayer First Act Overview 2\n7/21/2020\nC&L\nTaxpayer Experience Strategy Overview \n7/21/2020\nC&L\nTraining Strategy Overview \n7/21/2020\nC&L\nOrganizational Redesign Strategy Overview \n", "9.0 \| APPENDIX\n165\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n165\n165\n165\nIRS.gov\n11/13/2019\nC&L\nTaxpayer First Act Webpage\n11/21/2019\nTaxpayer Advocate \nService (TAS)\nNational Taxpayer Advocate (NTA) Blog: Highlights \nof the Taxpayer First Act and Its Impact on TAS and \nTaxpayer Rights\n9/1/2020\nTAS\nNTA Blog: Lessons Learned From COVID-19: The \nCritical Need to Improve IRS Digital Services\n9/2/2020\nC&L\nCreated TFA Resources and Guidance webpage\nNew Release\n12/13/2019\nC&L\nIRS: Recent legislation requires tax exempt \norganizations to eFile forms\n1/6/2020\nC&L\nIRS issues 2019 annual report; highlights program \nareas across the agency\n1/8/2020\nC&L\nNational Taxpayer Advocate delivers Annual Report \nto the Congress focuses on Taxpayer First Act \nimplementation, taxpayer service, and IRS funding\n2/3/2020\nC&L\nIRS launches Identity Theft Central\n3/13/2020\nC&L\nIRS announces waivers for Offer in Compromise \napplications\n5/15/2020\nC&L\nIRS expands partner materials for Economic Impact \nPayments (EIP); continues sweeping effort to share \ndetails in multiple languages\n5/20/2020\nC&L\nAndy Keyso named Chief of IRS Independent Ofﬁce of \nAppeals\n6/29/2020\nC&L\nNational Taxpayer Advocate Erin Collins delivers her \nﬁrst report to the Congress; identiﬁes COVID-19 \nchallenges, CARES Act, and Taxpayer First Act \nimplementation as priority issues for taxpayers\n7/21/2020\nC&L\nIRS creates new Enterprise Digitalization and Case \nManagement ofﬁce; Smith, Abold-LaBreche to serve as \nco-directors \n8/17/2020\nC&L\nNow available: IRS Form 1040-X electronic ﬁling\n8/24/2020\nC&L\nIRS updates procedures for designating taxpayer \ndisputes for litigation, implementing provisions of \nTaxpayer First Act \n8/28/2020\nC&L\nIRS approves temporary use of e-signatures for certain \nforms\n9/10/2020\nC&L\nIRS adds six more forms to list that can be signed \ndigitally; 16 now available\n", "9.0 \| APPENDIX\n166\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n166\n166\n166\nPodcast\n1/23/2020\nTFAO\nCarolina Credit Union League Tax Fraud Update (SL)\nTwitter @IRSNews\n12/23/2019\nC&L\nTFAO mailbox promo\n12/24/2019\nC&L\nTFAO mailbox promo\nTwitter @\nIRSSmallBiz\n12/22/2019\nC&L\nTFAO mailbox promo\nInternal \nCommunication \nVehicles\nPublish/\nCompletion \nDate\nBusiness Operating \nDivision\nTitle/Subject\nCongressional \nMeeting\n10/9/2019\nTFAO\nTFA Congressional Brieﬁng\n11/15/2019\nTFAO\nHouse Ways & Means Brieﬁng\n11/22/2019\nTFAO\nSenate Finance Committee Brieﬁng\n2/27/2020\nTFAO\nHouse & Senate Appropriations Brieﬁng\n3/4/2020\nTFAO\nHouse Ways & Means Brieﬁng\n3/5/2020\nTFAO\nSenate Finance Committee Brieﬁng\n3/5/2020\nTFAO\nSenate Homeland Security & Govt Affairs Brieﬁng\n4/22/2020\nTFAO\nEconomic Impact Payment Hill Staff brieﬁng\n9/16/2020\nTFAO\nHouse Ways & Means Committee Brieﬁng\n9/17/2020\nTFAO\nSenate Finance Committee Brieﬁng\nMeeting\n9/25/2019\nTFAO\nElectronic Tax Administration Advisory Committee \n(ETAAC) Listening Session\n10/9/2019\nW&I\nW&I Leadership & Council for Electronic Revenue \nCommunication Advancement Board Meeting\n10/16/2019\nTFAO\nGeneral Services Administration Engagement Session\n10/17/2019\nTFAO\nC&L National Public Liaison (NPL) Practitioner Meeting\n10/28/2019\nTFAO\nPhiladelphia Tax Practitioners Listening Session\n11/4/2019\nTFAO\nStockton University Veterans Resource Fair [via C&L \nStakeholder Liaison (SL)]\n11/5/2019\nTFAO\nETAAC Meeting\n11/12/2019\nTFAO\nOgden Tax Practitioner Listening Session\nTABLE 9.4.5 EXTERNAL OUTREACH ACTIVITIES\n", "9.0 \| APPENDIX\n167\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n167\n167\n167\nMeeting\n11/12/2019\nPublic Service Enterprise Group (PSEG) Social Service \nProfessional Conference (SL)\n11/14/2019\nTFAO\nAmerican Institute of Certiﬁed Public Accountants (AICPA) \nAdvocacy & Relations Committee\n11/14/2019\nCouncil for Electronic Revenue Communication \nAdvancement (CERCA) Annual Meeting\n11/19/2019\nTFAO\nNYC Tax Practitioner Listening Session\n11/20/2019\nTFAO\nLong Island Tax Practitioner Listening Session\n11/21/2019\nSB/SE\nNPL Practitioner Meeting \n11/21/2019\nTFAO\nTennessee Practitioner Liaison Meeting\n11/26/2019\nTFAO\nIRS National Security Awareness Week Roundtable - \nBrentwood (SL)\n12/2/2019\nTFAO\nMonday Tax Annual Update (SL)\n12/3/2019\nTFAO\nArizona National Association of Tax Professionals (NATP) \n2019 Tax Update - Tempe (SL)\n12/4/2019\nTFAO\nPractitioner Listening Session: El Monte, CA\n12/4/2019\nTFAO\nTaxpayer Advocacy Panel (TAP)\n12/5/2019\nTFAO\nLow Income Tax Clinic (LITC) Annual Conference\n12/6/2019\nTFAO\nArizona NATP 2019 Tax Update - Tucson (SL)\n12/9/2019\nTFAO\nOhio Society of Certiﬁed Public Accountant (CPA) Mega \nTax Conference (SL)\n12/11/2019\nSB/SE\nIllinois Practitioner Liaison Meeting\n12/11/2019\nTFAO\nIllinois Practitioner Liaison Meeting (SL)\n12/19/2019\nTFAO\nNY Bar Assoc. & State Local Taxation Committee Meeting \n(SL)\n1/7/2020\nTFAO\nETAAC Meeting\n1/7/2020\nTFAO\nUnited States Department of Veterans Affairs Meeting\n1/8/2020\nTFAO\nChattanooga Tax Practitioners Meeting (SL)\n1/10/2020\nTFAO\nGuilford Tech Community College Annual Small Business \nSummit (SL)\n1/10/2020\nTFAO\nUniv of Findlay Annual Income Tax School\n1/11/2020\nTFAO\nCA Society of Tax Consultants Running Start 2020 (SL)\n1/11/2020\nTFAO\nNJ State Tax Update (SL)\n1/14/2020\nSB/SE\nSmall Business Forum\n", "9.0 \| APPENDIX\n168\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n168\n168\n168\nMeeting\n1/14/2020\nTFAO\nAssociation of Former IRS Executives (AFIRE) Conference \nCall\n1/14/2020\nTFAO\nAZ Association of Accounting and Tax Professionals 2019 \nTax Updates (SL)\n1/14/2020\nTFAO\nInternal Revenue Service Advisory Council (IRSAC)\n1/14/2020\nTFAO\nLas Vegas Practitioner Liaison Meeting (SL)\n1/14/2020\nTFAO\nPA Society of Tax (SL)\n1/14/2020\nTFAO\nTFA Forums\n1/15/2020\nTFAO\nAriz. Practitioner Liaison Meeting (SL)\n1/15/2020\nTFAO\nConnecticut Practitioner Liaison Meeting\n1/15/2020\nTFAO\nTFA Forums \n1/16/2020\nTFAO\n2020 NVCPA Las Vegas Monthly Meeting (SL)\n1/16/2020\nTFAO\nABA (AICPA Mtg)\n1/16/2020\nTFAO\nAICPA Stakeholder Meeting\n1/16/2020\nTFAO\nFresno Practitioner Liaison Meeting (SL)\n1/16/2020\nTFAO\nH&R Block Session\n1/16/2020\nTFAO\nLatino Tax Pros (AICPA Mtg)\n1/16/2020\nTFAO\nME Practitioner Liaison Meeting (SL)\n1/16/2020\nTFAO\nNational Association of Tax Professionals (AICPA Mtg)\n1/16/2020\nTFAO\nNational Conference of CPA Practitioners (AICPA Mtg)\n1/16/2020\nTFAO\nNational Society of Accountants (AICPA Mtg)\n1/16/2020\nTFAO\nNational Society of Tax Professionals (NSTP)\n1/16/2020\nTFAO\nNevada Small Business Roundtable (SL)\n1/16/2020\nTFAO\nNPL Practitioner Meeting\n1/16/2020\nTFAO\nPadgett Business Services (AICPA Mtg)\n1/16/2020\nTFAO\nProsperity Now (AICPA Mtg)\n1/16/2020\nTFAO\nTax Executives Institute, Inc. (AIPCA Mtg)\n1/21/2020\nTFAO\nAlabama Tax Pros Web Conference (SL)\n1/22/2020\nTFAO\nMeeting with Social Security Administration (SSA)\n1/22/2020\nTFAO\nRhode Island Practitioner Liaison Meeting\n1/23/2020\nTFAO\nSC Dept of Revenue Employer Withholding Tax Workshop\n", "9.0 \| APPENDIX\n169\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n169\n169\n169\nMeeting\n1/23/2020\nTFAO\nSL Local Practitioner Web Conference (N. Calif.)\n1/23/2020\nTFAO\nTAP Focus Groups - International Taxpayers\n1/24/2020\nTFAO\nPA Practitioner Liaison Meeting (SL)\n1/27/2020\nTFAO\nFTA Membership Meeting\n1/28/2020\nTFAO\nAccounting & Financial Women's Alliance Annual Tax \nUpdate (Ariz., SL)\n1/28/2020\nTFAO\nStakeholder Liaison NY Practitioner Meeting\n1/29/2020\nTFAO\nIntuit Meeting\n1/29/2020\nTFAO\nNJ Practitioner Liaison Meeting (SL)\n1/30/2020\nTFAO\nDenver Practitioner Liaison Meeting (SL)\n1/30/2020\nTFAO\nDollarhide Community Center Business Roundtable (Calif., \nSL)\n1/30/2020\nTFAO\nJackson Hewitt Meeting\n1/31/2020\nTFAO\nEarned Income Tax Credit (EITC)/MCVET Event (Baltimore)\n1/31/2020\nTFAO\nCASH Campaign of MD- EITC Awareness Day Event - 10 \nAM - 11 AM / Maryland Center for Veterans Education and \nTraining-McVet site - Baltimore Accounts Mgmt Visit\n2/3/2020\nLB&I\nSilicon Valley Tax Director’s Group (SVTDG)\n2/3/2020\nTFAO\nSilicon Valley Tax Director’s Group (SVTDG)\n2/5/2020\nTFAO\nAFIRE Feedback Session\n2/5/2020\nTFAO\nPartnership for Public Service Meeting\n2/6/2020\nTFAO\nMonthly Payroll Industry Call\n2/7/2020\nTFAO\nTX Society of CPAs Practitioner Liaison Mtg (SL)\n2/11/2020\nLB&I\nAmerican Citizens Abroad Meeting (w/LB&I)\n2/11/2020\nTFAO\nReporting Agent Forum\n2/11/2020\nTFAO\nAmerican Citizens Abroad Meeting w/ LB&I\n2/12/2020\nTFAO\n2020 Long Island Tax Pros Symposium Planning (SL)\n2/13/2020\nTFAO\nNPL Practitioner Meeting\n2/24/2020\nTFAO\n2020 FTA Compliance Workshop\n2/25/2020\nTFAO\nDept of Veterans Affairs\n2/25/2020\nTFAO\nIndian Tribal Governments\n3/4/2020\nTFAO\nThe MITRE Corporation\n", "9.0 \| APPENDIX\n170\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n170\n170\n170\nMeeting\n3/5/2020\nTFAO\nAmerican Escrow Association\n3/9/2020\nTFAO\nFormer IRS Commissioner Rossotti\n3/10/2020\nTFAO\nFormer IRS Commissioner Koskinen\n3/13/2020\nTFAO\nFinancial Institutions Session\n3/13/2020\nTFAO\nPrivate Sector Outreach with Financial Institutions\n3/13/2020\nTFAO\nFinancial Institutions\n3/13/2020\nTFAO\nSenior Commissioner's Representatives Annual Executive \nMeeting\n3/17/2020\nTFAO\nAARP\n3/18/2020\nTFAO\nAmerican Bankers Association\n3/24/2020\nTFAO\nFormer IRS Commissioner Gibbs\n3/25/2020\nTFAO\nTaxpayer Opportunity Network \n3/31/2020\nTFAO\nAmazon.com, Inc.\n4/6/2020\nTFAO\nCanada Revenue Agency \n4/16/2020\nTFAO\nEIP Government Partners COVID-19 Communications Forum \n4/17/2020\nTFAO\nEIP Health Resources and Services Administration - Ofﬁce of \nHealth Equity\n4/21/2020\nTFAO\nEIP National Association of Counties\n4/24/2020\nTFAO\nEIP National League of Cities\n4/29/2020\nTFAO\nFormer IRS Deputy Commissioner for Services and \nEnforcement John Dalrymple\n4/29/2020\nTFAO\nFormer IRS Commissioner Doug Shulman\n4/29/2020\nTFAO\nIRSAC \n4/29/2020\nTFAO\nFormer IRS Commissioners - Koskinen, Rossotti, Gibbs, \nShulman\n4/30/2020\nTFAO\nEIP NPL Practitioner Meeting\n5/5/2020\nTFAO\nAmazon.com, Inc.\n5/6/2020\nTFAO\nUnited States Ofﬁce of Management and Budget (OMB)\n5/7/2020\nTFAO\nNational Conference of CPA Practitioners (NCCPAP)\n5/14/2020\nTFAO\nEIP U.S. Conference of Mayors\n5/15/2020\nTFAO\nUnited States Department of the Treasury (Treasury)\n5/19/2020\nTFAO\nAspen Institute\n", "9.0 \| APPENDIX\n171\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n171\n171\n171\nMeeting\n5/20/2020\nTFAO\nOMB\n5/21/2020\nTFAO\nNPL Practitioner Meeting\n5/26/2020\nSB/SE\nETAAC (SB/SE)\n6/2/2020\nTFAO\nTexas CPA Society (SL)\n6/9/2020\nTFAO\nIRS Security Summit \n6/10/2020\nTFAO\nOMB\n6/10/2020\nTFAO\nAmazon.com, Inc. Artiﬁcial Intelligence Demo\n6/19/2020\nTFAO\nPartnership for Public Service\n6/22/2020\nC&L\nTFA Forum “Save the Date”\n6/25/2020\nTFAO\nCERCA\n6/25/2020\nTFAO\nConsumer Financial Protection Bureau \n6/30/2020\nTFAO\nTreasury Assistant Secretary of the Treasury for Management\n6/30/2020\nTFAO\nUS Patent and Trademark Ofﬁce\n7/1/2020\nTFAO\nCivic Digital Fellows\n7/8/2020\nTFAO\nIRSAC\n7/9/2020\nC&L\nTFA Forum invitation \n7/15/2020\nTFAO\nTFA Forums\n7/16/2020\nTFAO\nTFA Forums\n7/22/2020\nTFAO\nIRS Geographic Leadership Communities\n8/6/2020\nSB/SE\nPayroll Industry Call (SB/SE)\n8/10/2020\nSB/SE\n“Hearing All Voices” Small Business Workshop and Listening \nSession\n8/12/2020\nTFAO\nCanada Revenue Agency \n8/12/2020\nTFAO\nAustralian Tax Ofﬁce\n8/18/2020\nSB/SE\nUtah State Tax Commission (Provision 2102)\n8/19/2020\nSB/SE\nConnecticut Department of Revenue Services (Provision 2102)\n8/26/2020\nSB/SE\nNational Association of Computerized Tax Processors \n(Provision 2102)\n8/26/2020\nTFAO\nColorado Taxpayer Advocate Service Group meeting\n9/9/2020\nSB/SE\nPennsylvania Department of Revenue \n9/10/2020\nSB/SE\nNew Jersey Department of the Treasury \n", "9.0 \| APPENDIX\n172\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n172\n172\n172\nMeeting\n9/10/2020\nTFAO\nIRSAC\n9/2/2020\nTFAO\nTreasury ASM Brieﬁng\n9/17/2020\nTFAO\nSoftware Developers Conference\n9/22/2020\nTFAO\nOMB\n9/24/2020\nTFAO\nTreasury Exec Secretariat Brieﬁng\n9/24/2020\nTFAO\nNPL Practitioner Meeting \nNationwide \nTax Forums\n7/21/2020\nTFAO\nVirtual Nationwide Tax forums TFAO Booth 7/21/20 – 8/21/20\nPayroll \nProfessional \nIndustry Call\n2/6/2020\nTFAO\nPayroll Industry Call\nPresentation\n1/31/2020\nTFAO\nHispanic Association of Professional Services Seminar (Calif., \nSL)\n2/3/2020\nTFAO\nPA Society of Tax Phila. Chapter Annual Tax Potpourri (SL)\n2/6/2020\nTFAO\nAsian Paciﬁc Community Summit 2020 Seminar for Business \nOwners (Calif., SL)\n2/6/2020\nTFAO\nNJ Society of CPAS (SL)\n2/6/2020\nTFAO\nPICPA Greater Philadelphia Federal Tax Committee (SL)\n2/6/2020\nTFAO\nSC Business Collaborative (SL)\n2/11/2020\nTFAO\nBetter Business Bureau Limited English Proﬁciency Event \n(Sacramento, SL)\n2/11/2020\nTFAO\nGeorgia Association of CPAs (SL)\n2/12/2020\nTFAO\nTax Tips for Small Businesses Workshop (Brooklyn, SL)\nReporting \nAgent \nForum\n11/13/2019\nSB/SE\nReporting Agent Forum\n5/12/2020\nTFAO\nReporting Agent Forum\n8/12/2020\nTFAO\nReporting Agent Forum \nTalking \nPoints\n10/8/2019\nTFAO\nPartnership for Public Service Keynote\n10/10/2019\nIT\nIT Industry Conference\n11/20/2019\nSB/SE\nLong Island Tax Professionals\n1/17/2020\nC&L\nFlorida Institute of CPAs Tax Conference\n1/24/2020\nC&L\nUniversity of California at Irvine Tax Symposium\n1/27/2020\nC&L\nUSC Tax Institute\n", "9.0 \| APPENDIX\n173\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n173\n173\n173\nTalking \nPoints\n2/27/2020\nC&L\nInternational Fiscal Association Conference - US Branch\n3/19/2020\nTFAO\nThank you note for former IRS Commissioners\n5/15/2020\nC&L\nNational Tax Symposium\n6/26/2020\nC&L\nTexas State Bar Association Annual Meeting\n6/30/2020\nC&L\nIRS Commissioner: Senate Finance Committee Hearing\n7/15/2020\nC&L\nTFA forums CIR talking points \n8/10/2020\nC&L\n“Hearing All Voices” Small Business Workshop and Listening \nSession\n", "9.0 \| APPENDIX\n174\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n174\n174\n174\nDIAGRAM 9.4.6 EXTERNAL COMMUNICATIONS \n AND OUTREACH \n ACTIVITIES ANALYSIS \n", "9.0 \| APPENDIX\n175\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n175\n175\n175\n9.5 COSTING METHODOLOGIES \n AND DETAILED COSTS \nThe Costing Methodologies and Detailed Costs sections contain pricing information for each \nstrategy. \n9.5.1 COSTING METHODOLOGIES\nThe Costing Methodologies Section outlines the process for how TFAO developed the pricing \nestimates for the three TFA strategies and other relevant enterprise-wide initiatives. \n9.5.1.1 TAXPAYER EXPERIENCE STRATEGY \n COSTING METHODOLOGY\nTo build a comprehensive cost estimate for the Taxpayer Experience Strategy the TFAO created \nsix components with approximately 140 capabilities. Capabilities were assigned to specifc out-\nyears, as prescribed in the legislation. \nThe TFAO convened a workshop of subject matter experts from across the IRS to develop cost \nestimates spread over the 1–2, 3–5 and 10-year timeframes mandated by the Act. During the \nworkshop, facilitators spent an equal amount of time presenting each of the six components and \nencouraged a two-way dialogue to ensure participants understood the scope and goals of each.\nThe IRS CFO leveraged the completed costing worksheets to compile the FY2022 budget and \nthe TFAO reviewed the FY2022 budget for gaps, redundancies, applicability and cohesiveness. \nAdditional meetings with business units were scheduled to clarify issues and adjust submissions. \nOnce all content issues were settled, the CFO compiled the business unit submissions for this \nReport and the FY2022 Treasury submission. Due to the high degree of overlap between the \nTaxpayer Experience Strategy and the IRS Modernization Plan, care was taken to deconfict \ncosts to ensure they were captured under one or the other, but never both. See Section 9.5.2.1 \nfor detailed costs of the Taxpayer Experience Strategy. \n", "9.0 \| APPENDIX\n176\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n176\n176\n176\n9.5.1.2 TRAINING STRATEGY COSTING \n METHODOLOGY\nThe Human Capital Office worked with the TFAO to create a FY2022 budget and out-year \ncosting using traditional methods and past practices to estimate labor, contractual support, and \ntechnology.\nThis same costing method was used for estimating the comprehensive Training Strategy’s seven \ncore capabilities that support a continuous learning environment and the implementation of the \nTaxpayer Experience Strategy. \nPart of the Training Strategy costing includes enhancements needed to use the Treasury \nIntegrated Talent Management System to implement new training technology and improve \nexisting technology-based training. See Section 9.5.2 for detailed costs of the Training Strategy.\n9.5.1.3 ORGANIZATIONAL REDESIGN \n STRATEGY COSTING METHODOLOGY\nThe Organizational Redesign Strategy outlined in Section 6 of this report is high-level, so the full \nscope and scale of TFA-related restructuring is unknown at this time. However, we determined \nthat we could estimate the full-scope costs of this restructuring by researching the costs \nassociated with a previous IRS restructuring effort, the IRS Restructuring and Reform Act of \n1998 (RRA ’98). The TFAO and CFO worked together to conduct the research and analysis of \nRRA ’98 to produce the initial cost assessment. These estimates adjust for infation as well as \nthe relative scope and scale of RRA ’98 to our current efforts. \nOur current assumptions for the Organizational Redesign Strategy scope include that it will be \na multi-stage reorganization and will be implemented over the course of fve years starting in \nFY2021\n. Estimated costs include drafting implementation plans, executing implementation plans, \nand IT costs. See Section 9.5.2.3 for detailed costs of the Organizational Redesign Strategy. \n", "9.0 \| APPENDIX\n177\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n177\n177\n177\n9.5.1.4 OPERATING DIVISION \n STRATEGY COSTING METHODOLOGY\nThe CFO gathered estimates from the operating divisions on the costs to implement ten of the \nremaining 42 TFA Provisions, outside of the Taxpayer Experience Strategy, Comprehensive \nTraining Strategy, and Organizational Redesign Strategy (See Section 9.3 for details on the \nOperating Divisions Provisions). Seventeen of the 42 provisions incurred additional costs to the \nIRS. IT Operation and Maintenance (O&M) and Program Support were also required. Provision \n2201 was self-funded with user fees.\nMany of the TFA requirements introduced signifcant changes to IT systems. The CFO has \nworked extensively with IT and the other business units to deploy and analyze the appropriate \ncosting and operational strategies. The CFO and operating divisions utilized the unit cost rate \ncalculator for labor requirements and estimated non-labor projections based on previous years’ \nactuals to generate a three-year costing plan to fully implement the TFA Provisions. See Section \n9.5.2.4 for detailed costs for the Operating Divisions Provisions.\n", "9.0 \| APPENDIX\n178\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n178\n178\n178\n9.5.2 ESTIMATED COSTS\nThe Estimated Costs Section outlines the estimated cost of the Taxpayer Experience, Training \nand Organizational Redesign Strategies from FY2021- FY2025. This Section also includes \nestimated costs of the Operating Division Provisions from FY2020-FY2025.\n9.5.2.1 TAXPAYER EXPERIENCE \n STRATEGY DETAILED COSTS\nTaxpayer Experience Strategy48 \nThousands of Dollars\nFY2021-FY2025\nTFA Costs\nExpand Digital Services\n337\n,000\nSeamless Experience\n378,000\nProactive Outreach & Education\n149,000\nCommunity of Partners\n68,000\nFocused Strategies for Reaching Underserved Communities\n54,000\nEnterprise Data Management & Advanced Analytics\n241,000\nTotals\n$1,227\n,000\n48 Cost estimates were formulated prior to enactment of 2021 appropriations\n", "9.0 \| APPENDIX\n179\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n179\n179\n179\n9.5.2.2 TRAINING STRATEGY DETAILED COSTS\nTraining Strategy\nThousands of Dollars\nFY2021-FY2025\nTFA Costs\nTraining on Organizational Awareness\n7\n,000\nTraining Tied to Career Paths\n13,000\n“People First” Training\n7\n,000\nEmployee Online Forum\n13,000\nOrganization Liaisons to Discuss Common Problems\n8,000\nInternal Concierge Service\n17\n,000\nEnhance Training Technology & Strategy Implementation\n58,000\nTotals\n$123,000\n9.5.2.3 ORGANIZATIONAL REDESIGN \n STRATEGY DETAILED COSTS \nOrganizational Redesign Plan/ TFAO Operations\nThousands of Dollars\nFY2021-FY2025\nTFA Costs\nTFAO\n36,000\nPlanning\n10,000\nImplementation\n70,000\nIT - Planning\n20,000\nIT - Execution\n80,000\nTotals\n$216,000\n", "9.0 \| APPENDIX\n180\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n180\n180\n180\n9.5.2.4 OPERATING DIVISION \n \u0001 \u0001\n \u0001\u0001\u0001PROVISION DETALED COSTS\nLegislatively Mandated Provision\nThousands of Dollars\nFY2020\nTFA Costs\nFY2021-\nFY2025 TFA \nCosts49\nTotal\nTFA Costs\n1001\nEstablishment of IRS Independent \nOffice of Appeals\n3,055\n42,000\n45,055\n1205\nPrivate Debt Collection and special \ncompliance personnel program\n495\n-\n495\n1206\nReform of notice of contact of third \nparties\n448\n-\n448\n1401\nReturn preparation programs for \napplicable taxpayers\n387\n-\n387\n1405\nWhistleblower reforms\n6,000\n6,000\n1406\nCustomer Service Information\n113\n-\n113\n2004\nCompliance by contractors with \nconfdentiality safeguards\n-\n4,000\n4,000\n2005\nIdentity protection personal \nidentifcation numbers\n49\n223,000\n223,049\n2101\nManagement of IT Information\n5,425\n-\n5,425\n2102\nInternet platform for Form 1099 \nflings\n8,736\n58,300\n66,736\n2201\nDisclosure of taxpayer information \nfor third-party income verifcation\n17\n,527\n-\n17\n,527\n2301\nElectronic fling of Returns\n34\n-\n34\n2302\nUniform standards for the use of \nelectronic signatures\n8,492\n14,000\n22,692\n2303\nPayment of taxes by debit and credit \ncards\n-\n6,000\n6,000\n2304\nAuthentication of users of electronic \nservices accounts\n-\n6,000\n6,000\n3101\nMandatory e-fling by exempt \norganizations\n3,127\n21,000\n24,127\n3201\nIncrease in penalty for failure to fle\n30\n-\n30\nn/a\nIT TFA Program Management Office\n13,736\n10,000\n23,736\nn/a\nIT Operations and Maintenance\n-\n148,000\n148,000\nn/a\nMisc non-IT costs\n5,823\n11,000\n16,823\nTotals\n$67\n,477\n$549,300\n$616,182\n49 Details do not add due to rounding.\n", "9.0 \| APPENDIX\n181\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n181\n181\n181\n9.6 TAXPAYER EXPERIENCE \n ADDITIONAL \n INFORMATION\nThis Section includes additional information including the Taxpayer Experience Strategy \nstrategic goals, capability groups and specifc capabilities.\nComprehensive Taxpayer Experience Framework\nGoals, Objectives, and Capability Descriptions\nCore Principles of the Comprehensive Taxpayer Experience Framework:\n1. Put Taxpayers First\n2. Facilitate Compliance and Ensure Fairness\n", "9.0 \| APPENDIX\n182\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n182\n182\n182\n9.6.1 STRATEGIC GOAL: UNDERSTAND, \n INFORM AND EDUCATE TAXPAYERS\n9.6.1.1 OBJECTIVE: PROVIDE CLEAR AND TIMELY \n COMMUNICATIONS\nPlease note that the asterisks indicate “key capabilities” that are featured in the \nTaxpayer Experience.\nCapability Group: Provide Proactive Outreach and Education\n\u0012\u000f\nYear-Round Communications: Communicate to taxpayers tax law changes, \nrequirements, guidance and impacts as well as send reminders during pre-filing, filing, \nand post filing activities (e.g\u000f, student aid and charity).\n\u0013\u000f\nShare Success Stories: Showcase IRS successes through various communication \nchannels.\n\u0014\u000f\nSocial Media Strategy: Use multiple social media platforms to share IRS news and \neducational updates that are customized based on demographics and other taxpayer \nbehavioral information. Social media will be used to engage taxpayers, guide them to the \nappropriate channel for service and communicate in a voice and style consistent with the \nrespective platform.\n•\nDiversity: Integrate a diverse array of taxpayers into communications.\n•\nLife Event-Specific Content: Create content specific to taxpayer life events (first \nemployment, marriage, retirement).\n•\nJourney Mappings: Develop use cases and focus on types of taxpayer’s \nexperiences.\n\u0015\n\u000f\nAnnounce Issue Campaigns: Proactively publicize common issues (e.g., non-\ncompliance).\n", "9.0 \| APPENDIX\n183\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n183\n183\n183\n5. Personalized Tax Updates:* Through online accounts, allow taxpayers to opt in to \nreceive personalized notifcations about changes to their tax situation, fling reminders or \nstatus updates for refunds, audits, and payments. Further developing online accounts, \nincreasing digital correspondence and providing more electronic reminders and \nnotices will help ensure taxpayers have up-to-date information to comply with their tax \nobligations.\n• \nPersonalized Information: Provide taxpayer notices and education related to their \nindividual tax status or circumstances. Allow taxpayer to save and use information \nspecifc to their personal situation.\n• \nTax Health Check: Leverage data to notify taxpayers of specifc tax campaigns and \nproactive alerts to potential non-compliance e.g. EITC, withholding changes, updates \nto tax calculators, identify upcoming status changes that may impact taxpayer fling.\n6. Service Channel Awareness: Provide taxpayers with information on what service tools \nare available to them and how to access them. \nCapability Group: Use Language T\naxpayers Understand\n7\n. Plain Language Communications:* Redesign notices and standardize correspondence \nacross the agency to simplify the format, educate and provide information to taxpayers \nin a manner that is easy to read and eliminate unnecessary legal language. Provide \nclear information and plain instructions to the taxpayers about why they are receiving \nthe communication from us, and what actions they need to take. This may also include \ninstructions for using online accounts for more detailed account information.\n8. Improve Counsel Guidance: Provide timely Counsel guidance in plain language. \n9. Simplifed Notices and Correspondence:* Analyze and use data to identify necessary \nlanguage translations for our notices and correspondence. Use data to improve the \neffectiveness of our communications in various taxpayer segments.\n10. Multi-Language Communications: Expand multi-language options for IRS \ncommunication channels and correspondence (e.g. forms, pubs, notices, letters, social \nmedia, emails, web content, phone, and web chat). \n", "9.0 \| APPENDIX\n184\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n184\n184\n184\n9.6.1.2 OBJECTIVE: UNDERSTAND TAXPAYER \n NEEDS\nPlease note that the asterisks indicate “key capabilities” that are featured in the \nTaxpayer Experience.\nCapability Group: Reach Underserved Segments\n11. Multilingual Strategy:* Develop customized strategies based on focused research that \nwill improve outreach, education, communications, and services to support taxpayers \nwith limited English.\n• \nTranslate Forms, Publications and Notices: Increase the languages available for \nmost widely used forms, publications and notices. \n• \nDigitally Aided Translation and Interpretation: Translate documents and phone \nconversations to other languages.\n• \nRecruitment: Increase incentives for prospective bilingual / multilingual employees’ \nand specify the languages we are looking for during hiring.\n• \nLeverage Employee Multi-lingual Skills: Incentivize employees to be certifed as \nmulti-lingual and recruit these employees to provide multi-lingual assistance and \nservices. \n• \nTranslation App: Enable better communication between feld employees and \ntaxpayers in their preferred language using a new translation application for mobile \ndevices.\n12. Armed Forces Strategy: Develop customized strategies based on focused research \nthat will improve outreach, education, communications, and services to support active \nduty Armed Forces, reservist, and veteran taxpayer’s needs. Leverage partnerships and \ninitiatives like W&I’s ‘adopt-a-base’ to expand access to service.\n13. International Strategy:* Develop customized strategies based on focused research that \nwill improve outreach, education, communications, and services to support International \ntaxpayers’ needs. Create new mechanisms and channels to provide service and \ncommunication options for individual and business taxpayers operating internationally. \n• \nInternational Online Account Authentication: Expand online account \nauthentication to international taxpayers to provide access to additional self-service \nchannels including the expanded digital tools and seamless experience described \nabove. \n• \nFocused Promotion of IRS eFile: Continue promoting IRS eFile to increase \nelectronic fling, expedite the fling process and reduce errors, ultimately improving the \ntaxpayer experience for international taxpayers.\n• \nVirtual Face-to-Face: Provide the ability for taxpayers to have a scheduled video \nchat with an IRS employee, using computer, tablet or mobile phone. \n", "9.0 \| APPENDIX\n185\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n185\n185\n185\n• \nVirtual Discussion Forums: Facilitate a new virtual discussion forum where \ntaxpayers can initiate discussions around fling requirements, rules, procedures and \nother topics. The forums will provide a moderated outlet for asking questions and \nsharing answers. International taxpayers will also have the ability to be a part of \nvirtual one-on-one or group conference via the forums. \n14. Native American Strategy: Develop customized strategies based on focused research \nthat will improve outreach, education, communications and services to support Native \nAmerican taxpayer’s needs.\n15. Persons with Disabilities: Develop customized strategies based on focused research \nthat will improve outreach, education, communications and services to support taxpayers \nwith disabilities. \n• \nExpanding Adaptive Services: Braille, sign language and other adaptive \ntechnologies.\n16. Elderly Strategy: Develop customized strategies based on focused research that will \nimprove outreach, education, communications and services to support elderly taxpayer’s \nneeds.\n17\n. Low-Income Strategy: Develop customized strategies based on focused research that \nwill improve outreach, education, communications and services to support low-income \ntaxpayer’s needs.\n18. Rural Strategy: Develop customized strategies based on focused research that will \nimprove outreach, education, communications and services to support rural taxpayer’s \nneeds.\nCapability Group: Leverage Taxpayer Feedback\n19. Continuous Feedback Loop: Expand avenues to collect real-time feedback from \ntaxpayers as they interact with all service channels to improve IRS products and services \nincluding: \n• \nInternal and External Feedback Mechanisms \n• \nAll phone calls, including those that do not result in Assistor Support \n• \nWebsite\n• \nOnline Applications (Online Account, Tax Professional Online Account) \n• \nIRS2GO Mobile App \n• \nExaminations\n• \nCollections \n• \nAppeals\n• \nLitigation \n20. Expand and Enhance Survey Capabilities: Give all taxpayer segments the opportunity \nto communicate feedback in real time via surveys on all IRS service channels to align \nwith PMA CAP CX Goal. \n21. Employ Taxpayer-Centric Design: Develop or leverage group(s) of volunteer taxpayers \n(e.g., Taxpayer Advocacy Panel (TAP)) to review all products and services at the idea, \nprototype, development, and test stages to provide usability and adoption feedback.\n", "9.0 \| APPENDIX\n186\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n186\n186\n186\n22. Leverage Taxpayer Advisory Panels: Expand the engagement and use of the Taxpayer \nAdvocacy Panel (TAP) or create new taxpayer advisory panels to collect taxpayer \nfeedback on new and enhanced IRS products and services. \n9.6.1.3 OBJECTIVE: BUILD TRUSTING \n RELATIONSHIPS AND PARTNERSHIPS\nPlease note that the asterisks indicate “key capabilities” that are featured in the \nTaxpayer Experience.\nCapability Group: Expand Federal Partnerships\n23. Co-Located Federal Government Services:* Partner with other federal agencies to \nallow the IRS to provide co-located services (e.g., post offices, U.S. embassies, etc.). \nThese partnerships could apply to both service and compliance interactions.\n24. Data Sharing Opportunities:* Ensure secure and authorized information-sharing \nwith federal and state agencies, Security Summit participants and other third parties \nwithin the boundaries of the established law to allow us to incorporate new sources of \ninformation from a secure network to drive enforcement decisions, combat identify theft \nand improve the taxpayer experience.\n25. Federated Authentication: Simplify identity proofng and authentication for taxpayers by \nunifying authentication across more agencies.\n26. Leverage Customer Service Best Practices: Work with our partners to develop and \nshare customer service research and best practices.\n27\n. Leverage Community Outreach Best Practices:* Work with our partners to beneft \nfrom their experience in developing community partnerships, such as joining with other \nagencies to learn how they access hard-to-reach communities.\nCapability Group: Expand Community Presence and Industry Partnerships\n28. Expand VITA and TCE Partnership:* Expand and promote the Volunteer Income Tax \nAssistance (VITA) and Taxpayer Counseling for the Elderly (TCE) programs including \ngeographic presence, availability (dates which they are open), scope of supported \nissues and taxpayers that qualify. \n29. Tax Education in Schools: Partner with education institutions to develop, deliver, and \npromote tax education using tools like the Understanding Taxes Simulator.\n30. Expanding Community Presence:* Cultivate trusted relationships with local leaders, \ncommunity centers, cultural and faith communities and organizations and chambers of \ncommerce to help us provide outreach, education and other services. This collaboration \nwill also help us better reach populations that may be underserved or under-represented.\n31. Building and Expanding Trusted Stakeholder Network:* Use existing partnerships \nand develop new ones to improve information-sharing between organizations and \ncollaborate on solving common problems. \n", "9.0 \| APPENDIX\n187\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n187\n187\n187\n32. Expand LITC Partnerships: Expand and build partnership with LITC to fnd new and\nbetter way to serve Low Income Taxpayers.\nCapability Group: Improve IRS Image\n33. Improve Image: Improve the perception of the IRS by highlighting both taxpayer service\nand enforcement activities.\n34. Establish Broader Organizational Goals and Metrics: Develop measures that span\nacross the organization.\n35. Customer Service Tied to Performance Measures: Implement additional executive,\nmanagement and employee performance measures tied to taxpayer experience\noutcomes.\n36. Celebrate and Award Excellent Customer Service: Create additional program that\nrecognizes and awards excellent customer service. Share these stories both internally\nand externally.\n37\n. Share Improvements Publicly: Share improvements with the public and explain what\nthey mean for the taxpayer experience.\n38. Raise Public Awareness of CI Outcomes: Expand communications and public\nawareness of criminal investigation cases to demonstrate a fair and just tax system.\n9.6.2 STRATEGIC GOAL: PROVIDE A SEAMLESS \nTAXPAYER EXPERIENCE\n9.6.2.1 OBJECTIVE: INCREASE A$$ESS \nAND PROMOTE TRANSPARENCY\nPlease note that the asterisks indicate “key capabilities” that are featured in the \nTaxpayer Experience.\nCapability Group: Enhance Self Service\n39. Improve Search-Driven Website: Use search-optimized content and natural language\nprocessing (NLP) to understand questions framed by taxpayers.\n40. Enhanced FAQ Page: Leverage taxpayer data to personalize FAQ recommendations.\n41. Forms Database: Improve interface for locating forms with robust search and tags.\n42. Forms Engine: Implement technology on IRS.gov that recommends and locates\napplicable forms and publications for the taxpayer.\n43. Mobile Phone Push Notifcations: Provide opt-in mobile phone push notifcations from\nthe IRS for MeF return fling, “Where’s My Refund,” ECM case status, etc.\n44. IRS2GO Full-Functionality of Online Account: Increase the functionality of Online\nAccount through the IRS2GO app.\n", "9.0 \| APPENDIX\n188\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n188\n188\n188\n45. Change Account Information (“Self-Correct Entity”):* Allow taxpayers to update their \ncontact information and other key details.\n46. Taxpayer View History:* Allow taxpayers to see information about their tax histories \n(e.g. refunds, payments received, amounts owed, returns fled, etc.) through their online \naccounts to ensure transparency and accessibility of records.\n47\n. Digital Amended Returns: Allow taxpayers to amend their returns online after receiving \nnotifcations on required updates or errors; possibly align with digital notices with click-to-\ncorrect capabilities.\n48. Improve Online Installment Agreements: Provide taxpayers with an improved \nmechanism for setting up a payment plan they are eligible for within their Online Account.\n49. Integrate Refund Tracking: Integrate “Where’s My Refund” into online accounts and \nIRS2GO app.\n50. Issue Resolution Tracking: Create an automated tool that provides current status and \nnext steps of any issue or case. \n51. Link a Bank Account: Enable taxpayers to link their bank accounts to their Online \nAccount giving them the ability to seamlessly send or receive money from their checking \nor savings account.\n52. Expand Payment Options: Provide taxpayers, businesses and tax professionals the \nability to make payments through all channels including telephone, online accounts, \nmobile apps and walk-in assistance. Electronic Funds Transfer (EFT) and credit and \ndebit cards interactions will remain available as well.\n53. Expand Electronic Distribution of Refunds: Add more options to deliver tax refunds \nelectronically with the goal of eliminating paper checks.\n54. Digital Notifcations:* Generate customized taxpayer notices and letters accessible \nthrough online accounts. Taxpayers will be able to opt in to receive personalized \nnotifcations about changes to their tax situation, payment reminders and status updates \non refunds or audits.\n55. Subscription Service to Opt-In to Receive Notifcations: Allow taxpayer to enable \nand receive notifcations to their email account and/or mobile devices.\n56. Connection to Tax Pro Account: Allow taxpayers to grant accountants, tax preparers \nand other third parties access to their Online Account.\nCapability Group: Enhance Assisted Services\n57\n. Wait Time Transparency:* Provides taxpayers estimated wait times to inform their \ndecision on whether to remain on hold, opt for a call back or seek information on \nIRS.gov.\n58. Expand Automated Callback:* Allows taxpayers to provide their telephone number and \nopt for an IRS employee to call them back instead of waiting on hold.\n59. Improved Menu System and “Phone Tree”: Provide taxpayers with an easy to use \nphone tree including simplifed menu options.\n60. Human Phone Voice (for IVR Phone Menu System): Use an AI representative to \nenable a more consistent, authentic and less robotic automated system with greater \nagility to make changes.\n", "9.0 \| APPENDIX\n189\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n189\n189\n189\n61. Language Options for Phoneline: Offer easily accessible multi-language options to\ncallers.\n62. Improved Service on Practitioner Priority Line: Monitor and add resources as\nnecessary to improve service at peak times.\n63. Voice Bot: Leverage AI solutions to recognize human language to provide solutions and\ndigital telephonic assistance.\n64. Notice Access: Provide employees the ability to see all notices for the taxpayer they are\nassisting.\n65. Expand Digital Kiosk: Provide access to IRS Online Self-Service Tools at all TACs,\nfederal buildings and partners:\n•\nLive Assistor: Passive staffing (e.g. receptionist) to handle questions if needed,\nvideo conference capability.\n•\nIn-Person Authentication: Allow in-person authentication in cases where online\nauthentication is unsuccessful.\n•\nPrinter Connection: Enable printer connection for printing of transcripts, notices,\netc.\n•\nCredit Card Payments: Accept credit card payments with no fees.\n66. Virtual Face-to-Face: Provide the ability for taxpayers to have a scheduled video chat\nwith an IRS employee, using computer, tablet, or mobile phone.\n67\n. Click to Call-VOIP: Create the ability for a taxpayer that is having difficulty resolving an\nissue in the web environment to connect to an IRS employee with one click.\n68. Counsel Settlement Day: Invite Appeals, Collection and TAS to provide one stop\nresolution for taxpayers.\nCapability Group: New Service Channels\n69. Tax Professional Online Account:* Provide online accounts for tax professionals,\nwhich allow eligible representatives to access client information and services.\n•\nAdd Authorization and POA/Fully Digital CAF: Enable e-Signature for real-time\napproval of Authorization and POA.\n•\nUpdate/Remove Authorization and POA: Create the ability to add and remove\nclient authorizations and POA.\n•\nList of Clients with Access to OLA: Develop an aggregated list of clients that a\nPOA has authorization to represent during a specifed tax period.\n•\nAccess to Taxpayer Notices History: Allow tax professionals to view all client\nnotices.\n•\nPractitioner Premium Access: Offer live chat, digital request for callback and other\ncommunication tools.\n•\nAct on Behalf of Client: Enable Tax Pros to view information and take any actions\nthat their clients can take in their individual OLA.\n70. Digital Newsroom: Develop a digital newsroom that provides regular updates about\nlegislative and tax code changes to tax pros. This newsroom will enable IRS partners to\nanticipate and answer taxpayer questions in a way that is consistent with IRS language\nand expectations.\n", "9.0 \| APPENDIX\n190\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n190\n190\n190\n71. APIs for Third Parties: Develop capability for third parties (e.g., software providers) to \ninterface and share data with IRS such as:\n• \nRefund Status: Push notifcation from “Where’s My Refund”\n• \nRealtime Transcript Access: e-Signature for authorization for a new taxpayer client \nbuilt-in\n• \nCase Status: Push notifcation from ECM\n• \nPayment API: Leverage payment options for the taxpayer\n72. Business Online Account: Provide online accounts and services for businesses.\nCapability Group: Enable Omnichannel Experience\n73. Concierge Navigation Support:* Gives taxpayer-facing IRS employees the ability \nto provide taxpayers with the information they need or personally connect them with \na subject matter expert who can assist. Each employee will receive calls and handle \ncontacts based on the nature of the issue identifed in the web chat, through topic-based \nrouting on the phone or during casework contacts. The employee will resolve all issues \nwithin the scope of their training and expertise. If the initial employee cannot provide \nthe assistance the taxpayer is looking for, the employee will smoothly transition the \ntaxpayer to a subject matter expert with the knowledge and authority to handle the type \nof taxpayer assistance required.\n74. Assistor-Powered Chat: Expand the ability for an employee to web chat with taxpayers. \n75. Web and Mobile Video Chat: Launch a virtual face-to-face video chat option with IRS \nemployees to simulate an in-person appointment for those that require a human touch \npoint but are unable to or prefer not to meet in person.\n76. Artifcial Intelligence (AI)-Powered Informational Web Chat (Virtual Assistance):* \nAllows for an AI-powered chat bot to attempt to answer questions or direct the taxpayer \nto helpful information on IRS.gov or to their online account based on a taxpayer’s \nbrowsing preferences on IRS.gov. Chat bots will also be able to connect taxpayers to \nan IRS assistor for a web chat or voice call. The chatbot will improve over time as the \nknowledge base expands and more taxpayer experience feedback becomes available. If \nthe chatbot cannot resolve a taxpayer’s issue, contact routing will guide the taxpayer to \nlive support from an IRS employee. \n77\n. AI Engages IRS Assistor: Alert IRS employees and launch web chat with taxpayers \nwhen an issue is not resolved by chat bot. \n78. AI-Powered Transactional Chat: Bot supports the taxpayer in performing tasks such as \nmaking payments, flling out forms, scheduling callbacks, schedule virtual or face-to-face \nappointments.\n79. AI-Powered Digital Appointments:* Allows taxpayers to speak with an assistor \nor schedule an appointment if the chatbot is unable to resolve a taxpayer’s issue. \nTaxpayers will also be able to schedule AI-Powered appointments with employees in \nother IRS organizations, like exam and collection. The chatbot will be able to determine \nif an assistor is needed and either “introduce” the caller to an assistor or schedule an \nappointment with an employee for a later time. The appointment could be with a service \nor compliance employee and can be in-person, telephonic, or via secure video chat. \n", "9.0 \| APPENDIX\n191\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n191\n191\n191\n80. Virtual Assistant Optimized Content: Make content from IRS.gov searchable by Virtual \nAssistants (VAs) like Alexa, Siri, or Cortana using artifcial intelligence. Taxpayers would \nbe able to ask the VA their tax questions and it would use natural language processing \n(NLP) and AI to answer questions based on information from IRS.gov.\n81. Seamless Phone Assistor Transfer: Case details and conversation history travel with \nthe taxpayer from employee to employee as they are transferred to enable seamless \nphone transfers. \n82. Enhanced Tiered Support: Provide tiered levels of support and training. Tier two \nemployees address more complicated out of scope questions during fling season. Tier \nthree employees are subject matter experts ready to address more difficult or unique \ntaxpayer questions. Skill codes identify SMEs by topic.\n83. Expand Use of Scheduling Tool: Provide all employees with the ability to make an \nappointment for the taxpayer with another employee/SME.\n9.6.2.2 OBJECTIVE: SIMPLIFY THE TAX PROCESS\nPlease note that the asterisks indicate “key capabilities” that are featured in the \nTaxpayer Experience.\nCapability Group: Expand Digital Filing\n84. Promote Free File: Promote the free fle program in LITCs, TACs, community centers, \nschools, and other community presence expansion efforts.\n85. Digitize All Tax Forms: Continuously increase toward goal that all forms are digital. \n86. Expand eFile options: Further expand the opportunity for taxpayers to fle forms \nelectronically. \n87\n. Digital Signatures:* Allow authenticated individual taxpayers and representatives to \nsubmit electronic signatures via online accounts.\n88. Tax Credit Estimator: Develop a calculator tool to determine which tax credits taxpayers \nqualify for and estimate what amount of credit taxpayers might expect (e.g., Digital \nversions of Schedule R, Schedule 8812, Schedule H, or other Schedules).\nCapability Group: Resolve Issue Timely\n89. Secure Document Exchange:* Allow taxpayers, businesses, tax professionals and IRS \nemployees to securely upload and access documents in a centralized repository. \n90. Errors, Next Steps and POC Addition: Provide an explanation for the correspondence \nor audit with clear actions for taxpayer to follow, as well as resources if the taxpayer \nneeds help, including a designated point of contact.\n91. Confrmation Number/Barcode on Notices: All notices include a confrmation number \nlinked to the taxpayer’s case fle to speed up the assistance process and a QR code that \ncan be scanned to access additional information about the circumstance that generated \nthe notice.\n92. Including Relevant Links: Include specifc links to relevant online resources in all IRS \nelectronic notices.\n", "9.0 \| APPENDIX\n192\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n192\n192\n192\n93. Reduce Time Between Filing and Audit: Reduce the length of time between when a \ntaxpayer fles and if they are audited.\n94. Secure One-Way Messaging: Notify taxpayers of upcoming deadlines, fling errors, and \nbalance due situations. Taxpayers would receive an email prompting them to log in to \ntheir Online Account to review the new messages.\n95. Secure Two-Way Messaging:* Give taxpayers the ability to communicate with IRS \nemployees through their online accounts.\n96. Consistent Audit Steps for Same Issue: Ensure the taxpayer gets consistent service \nacross audits.\n97\n. Provide Account Managers to Large Businesses: Provide a dedicated account \nmanager for large business taxpayers or dedicated access points for general service \ninquiries.\n98. New Processes to Achieve Early Tax Certainty: Develop processes for the IRS to \nprovide large businesses earlier tax certainty.\n• \nCreate additional opportunities for taxpayers from large business to resolve \ncompliance issues outside the audit process. Send closing letters/messages when \naudit complete, similar to estate tax audits.\n99. Improve Issue Routing: Streamline the assignment and routing of issues to eliminate \ngaps in the IRS process \n100. Post-File Issue Resolution Program: Develop processes for large business to resolve \nissues outside of the audit process.\n9.6.3 STRATEGIC GOAL: EMPOWER, EQUIP & \n ENABLE WORKFORCE\n9.6.3.1 OBJECTIVE: INCREASE \n EMPLOYEE KNOWLEDGE AND \n EXPERIENCE\nPlease note that the asterisks indicate “key capabilities” that are featured in the \nTaxpayer Experience.\nCapability Group: Enhance Employee T\nraining50\n101. Training on Organizational Awareness: All employees should be given initial and \nperiodic organizational training to reduce the knowledge gap as to what goes on in \ndifferent organizational units.\n50 These are capabilities specifcally identifed during listening sessions where we heard that focused training is needed \nin support of pursuing a better taxpayer experience. These capabilities are also included as a part of our overall Training \nStrategy detailed in Section 5 of this Report.\n", "9.0 \| APPENDIX\n193\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n193\n193\n193\n102. Training Tied to Career Paths: Align training opportunities and career goals to \nempower employees to advance in their career.\n103. “People First” Training: Train employees to incorporate plain language, civility and \nempathy when speaking with taxpayers. \n104. Employee Online Forum: Create collaborative digital platform to share best practices \nand answers to both common and unique problems. Employees can ask questions and \nseek answers from other IRS colleagues, and solicit knowledge across the organization \nleading to improved knowledge management across the IRS.\n105. Organization Liaisons to Discuss Common Problems: Establish subject matter \nexperts that represent parts of the IRS and collaborate to resolve internal process and \nprocedural issues as well as taxpayer issues (e.g. expand W&I’s CEWS system).\n106. Internal Concierge Service: Create internal concierge service to help guide employees \nto the appropriate resource in the IRS (e.g. Ask Audrey concept). \n9.6.3.2 OBJECTIVE: EQUIP EMPLOYEES \n WITH THE TOOLS NECESSARY \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n TO PROVIDE \n EXCELLENT TAXPAYER SERVICE\nPlease note that the asterisks indicate “key capabilities” that are featured in the \nTaxpayer Experience.\nCapability Group: Provide Concierge Service\n107\n. 360 Degree View of Taxpayer Accounts:* Provides IRS employees with a global \nview of each taxpayer account and gives them access to taxpayer records in real-time, \nincluding interaction history, appointment schedules, etc. This will be available through \nan ECM system.\n108. Ability for Two Assistors to View Info When Transferring Taxpayer: Ability for IRS \nemployees to see real-time taxpayer interactions that fow with them as they move from \none-channel to another, including transfers.\n109. Accessible Analytics Reports on Taxpayers: Data on taxpayers is accessible for \nreporting. Employees can create customized, cross-functional reports for assisting and \nimproving their taxpayer service.\n110. AI-Powered Employee Assistant:* Supports IRS employees when answering \ntaxpayers questions with an AI-powered knowledge base that will make suggestions \nbased on a taxpayers experience, questions or pages visited on IRS.gov. \n111\n. Robust Analytics on Digital Interactions: Track taxpayer interactions from IRS.gov to \nonline accounts to reveal taxpayer behavior online, where they engage, and where they \ndisengage. Will inform Outreach content strategy.\n", "9.0 \| APPENDIX\n194\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n194\n194\n194\n112. Record Entire Taxpayer Experience for Analysis: Accumulate the data to provide an \naccurate representation of the entire taxpayer experience and then use the analysis to \nkeep improving customer service.\n113. Knowledge Base: Provide an expansive knowledge base for IRS employees, which \nwill include videos, interactive learning, guidance and best practices (could tie to AI \nEmployee Assistant).\n114. Resolution Guides: Employees have access to “Micro Trainings” and interactive guided \nresolution tours to help taxpayers resolve specifc issues.\n9.6.3.3 OBJECTIVE: EMPOWER EMPLOYEES \n TO RESOLVE TAXPAYER ISSUES\nPlease note that the asterisks indicate “key capabilities” that are featured in the \nTaxpayer Experience.\nCapability Group: Simplify Internal Processes and Procedures\n115. Improve the Clarity and Usability of Internal Guidance: Review and revise IRMs to \nuse plain language and eliminate IRM-to-IRM conficts.\n• \nRe-engineer the IRM: Conduct an analysis to identify opportunities and establish \nimproved methods for how the IRM is developed, updated and distributed.\n• \nRemove Inconsistencies and Conficts: Review all IRMs end-to-end and remove \ninconsistencies and conficts that inhibit a seamless taxpayer experience.\n• \nCentralize and Streamline IRM Access and Publication: Modify Publishing \nProcesses to Allow for More Rapid Updates/Corrections.\n• \nCentralize IRM Feedback Process: Develop an IRM feedback process allowing \ntransparency and responsiveness.\n• \nInternal Plain Language Communications: Establish organizational plain language \nreviewers to ensure content is clear and understandable.\n• \nIdentify SMEs/Authors: Identify SMEs and Authors internally to facilitate making \nmodifcations when necessary.\n116. Streamline New Changes to Pubs, Letters, Notice, and Forms: Create more agility in \nability to change pubs, letters, notices and forms.\nCapability Group: Increase Employee Authority to Resolve Issues\n117\n. Redesign Position Descriptions and Core Job Elements for Workforce: Update \nposition descriptions and core job elements to embrace taxpayer frst and emphasize \nearliest resolution of issues. \n118. Adjust Quality Review Process: Currently some employees get quality errors for \nanswering out of scope questions and providing service that is provided by another \nsegment of the organization. Shift to rewarding employees for resolving taxpayer issues \nrather than penalizing them.\n", "9.0 \| APPENDIX\n195\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n195\n195\n195\n119. Issue De-Escalation Process: Create informal review process for taxpayers to pursue\nbefore taking next steps in a formal process (e.g., exam/appeals).\nCapability Group: Provide Clear Point of Escalation and Resolution to Taxpayer \n120.Dispute Resolution Process: Identify IRS employees that have the capability and\nauthority to resolve any taxpayer issue before going to Appeals or Taxpayer Advocate\nService.\n121. Clear Identifcation of SMEs to Escalate Issues: Provide a clear process of where\nand who to route cases to if there is an issue.\n122.Reimplement Problem Resolution Day: Create specifc days during which taxpayers\ncan bring in (virtually or in person) complex, multifunctional issues. IRS will have a set of\nSMEs available in person or virtually to resolve issues collaboratively in real time.\nCapability Group: Improved Data Analytics\n123.Capturing a Comprehensive Set of Data Assets:* Advance data access, usability,\nand governance to inform decision making and improve operational outcomes across\nthe enterprise. To make this happen, the IRS will iteratively expand its data environment,\nto include making data more readily accessible through transition from paper to digital\nenvironment, allowing analysts to solve data-driven problems faster. This comprehensive\ndata repository will be built on fundamental data collection principles of gathering,\ndefning, perfecting, and storing information. This will inform better compliance\nenforcement decisions, which will in turn reduce the burden on compliant taxpayers and\ndirect IRS enforcement resources more strategically.\n124.Employing Advanced Data Analytics:* Analyze behavioral research and other\ndata to better identify and separate taxpayers who are trying to comply from those\nwho are intentionally violating our tax laws, minimizing compliance contacts where\ndirect enforcement activity wouldn’t be necessary. This will also help us avoid placing\ncompliant taxpayers into compliance treatments while enhancing detection of\nnon-compliant taxpayers so we can respond appropriately to encourage compliant\nbehavior.\n", "9.0 \| APPENDIX\n196\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n196\n196\n196\n9.6.4 ENABLERS\nThe following enablers list the resources necessary to implement the Taxpayer Experience \nStrategy and ensure success:\n• \nFunding: Costing will be refected in the report at various level of detail and appropriation \nrequests will refect specifc capabilities and initiatives needed to advance the Taxpayer \nExperience Strategy. Changes to the current appropriation process would facilitate \nimplementation of capabilities that extend beyond a single fscal year and bridge across \nservice enforcement and support areas. \n• \nCulture Transformation: As IRS has a mission culture in some cases this has resulted \nin siloed operation and a lack of enterprise-wide strategies. Implementing Taxpayer \nExperience Strategy, Training Strategy, and necessary changes to organizational \nstructure will require signifcant change leadership. \n• \nPolicy Changes such as IRM Changes: Many of the aspects of the strategy will \n \nrequire policy and procedural changes. We have also identifed an opportunity for the \nagency to become nimbler in adopting changes to policy and procedure. \n• \nOrganizational Redesign: Several components of the Taxpayer Experience Strategy \nwill only be effective when coupled with organizational change details discussed in the \nOrganizational Redesign Section. \n• \nTraining: There are training aspects to all components of the Taxpayer Experience \nStrategy. Training Strategy is discussed in detail in the report.\n• \nHiring and Talent: The IRS must identify and develop/acquire appropriate staffing \nresources to fll the gaps identifed in the Taxpayer Experience Strategy.\n• \ne-Signature \n• \nContent Management Platform (UNS CCSD Customer Contact Center)\n• \nAgile Development\n• \nHuman Centered Design\n• \nEnterprise Case Management (ECM)\n• \nDigital Communications Platform\n• \nAuthorization Framework\n• \nAPI Platform \n• \nFull Integration of Data for Digital Applications\n• \nCentral Data Repository\n• \nRobotics Process Automation\n• \nCloud Execution\n• \nBusiness Process Re-engineering\n", "9.0 \| APPENDIX\n197\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n197\n197\n197\n9.6.5 INTERNAL REVENUE MANUAL ADDITIONAL \n INFORMATION\nUpdating appropriate IRM Sections will include the following components: \n1. Review capabilities, priorities and organizational changes in the Taxpayer Experience \nand Training Strategies\n2. Coordinate work to ensure all relevant IRM Sections are identifed for revisions and \nupdates\n3. Consult with executives, subject matter experts and appropriate stakeholders on \nnecessary program changes for required IRM Sections\n4. Reach agreement with all parties on detailed procedural, program, or operational \nchanges associated TFA capabilities, priorities and organizational changes \n5. Develop necessary content, including interim guidance, for required IRM Sections\n6. Write, revise and edit the new content following established plain language standards\n7\n. Ensure new content aligns and does not create conficting guidance\n8. Ensure all revised IRM Sections contain management and internal controls\n9. Update IRM Section dates to notate revised content\n10. Ensure all clearance, approval and publishing activities are successfully completed\n", "9.0 \| APPENDIX\n198\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n198\n198\n198\nThis Section includes additional information on the Organizational Redesign Strategy, such as \nthe major structural changes’ alignment to oversight recommendations.\nOverview of Oversight and Advisory Organizations\nThe Treasury Inspector General for Tax Administration (TIGTA) represents the executive branch \nof Federal Government within the Department of Treasury by providing audit and investigative \nservices that promote economy, efficiency and integrity in the administration of the internal \nrevenue laws. As part of the IRS Restructuring and Reform Act of 1998, TIGTA was established \nto provide independent oversight of IRS activities. TIGTA\n’s focus is devoted entirely to tax \nadministration.51 \n \nThe Government Accountability Office (GAO), representing the legislative branch of government, \nis an independent, non-partisan Agency that works for the Congress. GAO acts as investigative \narm of the Congress by studying the programs and expenditures of the Federal Government. \nGAO performs their audits at the request of Congressional committees or subcommittees or a \nmandate by public laws or committee reports.52 Like TIGTA, GAO is also granted authority to \nconduct audits and review IRS programs and business processes.\nThe Office of Management and Budget (OMB) assists the President in the development and \nimplementation of budget, program, management, and regulatory policies. It conducts in-depth \nregulatory review of signifcant rules proposed by federal agencies as well as promotes best \npractices management across the Federal Government. OMB provides guidance on preparation, \nsubmission, and execution of the IRS budget.53\nThe Taxpayer Advocate Service (TAS) is an independent office within the IRS, led by the \nNational Taxpayer Advocate (NTA). Its main purpose is to protect taxpayers’ rights and help \ntaxpayers resolve problems with the IRS. The NTA presents an Annual Report to Congress \nhighlighting the 10 most serious problems facing taxpayers as well as administrative and \nlegislative recommendations to mitigate those problems.54\n9.7 ORGANIZATIONAL REDESIGN \n ADDITIONAL INFORMATION\n51 Treasury Inspector General for Tax Administration, About TIGTA.\n52 U.S. Government Accountability Office, About GAO.\n53 Office of Management and Budget, About Office of Management and Budget.\n54 National Taxpayer Advocate, Taxpayer Advocate Service, About TAS.\n", "9.0 \| APPENDIX\n199\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n199\n199\n199\nThe Electronic Tax Administration Advisory Committee (ETAAC) conveys the public’s perceptions \nof the IRS electronic tax administration activities, offers constructive observations about \ncurrent or proposed polices, programs, and procedures, and suggests improvements. ETAAC \nprovides an annual report to the Congress on IRS progress in support of the overriding goal that \npaperless fling should be the preferred and most convenient method of fling tax and information \nreturns.55\nThe Internal Revenue Service Advisory Council (IRSAC) advises the IRS on issues that have \na substantive effect on federal tax administration. The IRSAC reviews existing practices and \nprocedures and makes recommendations on both existing and emerging tax administration \nissues. The IRSAC provides an annual public report that proposes enhancements to IRS \noperations, recommends administrative and policy changes to improve taxpayer service, \ncompliance and tax administration, discusses relevant information reporting issues, addresses \nmatters concerning tax-exempt and government entities and conveys the public’s perception of \nprofessional standards and best practices for tax professionals.56\nThe Taxpayer Advocacy Panel (TAP) listens to taxpayers, identifes taxpayers’ issues and \nmakes suggestions for improving IRS service and customer satisfaction. The TAP acts as a \ntwo-way channel between the IRS and the general public by sharing taxpayer feedback and \nworking closely with IRS employees to resolve issues and monitoring progress in implementing \nsolutions.57\nThe IRS Oversight Board was created by the Congress under the IRS Restructuring and Reform \nAct of 1998. The Oversight Board is a nine-member independent body charged to oversee the \nIRS in its administration, management, conduct, direction, and supervision of the execution and \napplication of the internal revenue laws and to provide experience, independence, and stability \nto the IRS so that it may move forward in a cogent, focused direction. The Oversight Board does \nnot currently have enough members confrmed by the U.S. Senate to make up a quorum and as \na result has suspended operations. 58\n55 IRS.gov, Electronic Tax Administration Advisory Committee (ETAAC).\n56 IRS.gov, Internal Revenue Service Advisory Council (IRSAC).\n57 Taxpayer Advocacy Panel, About Us.\n58 IRS Oversight Board, About Us.\n", "9.0 \| APPENDIX\n200\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n200\n200\n200\n9.7.1 COMMISSIONER DIRECT REPORTS \n ALIGNMENT TO \n OVERSIGHT RECOMMENDATION\nThroughout this process, we have gathered signifcant research, feedback, and insights to help \ninform our proposed strategy. As we analyzed the tremendous amount of information gathered, \nwe also reviewed historical documents and previous recommendations from the Chief Risk \nOfficer, oversight audits, and our stakeholders to ensure that we considered past learnings and \ncritical challenges. This Section elaborates on the details of the Commissioner Direct Reports \nfound in Section 6.3 and describes the strategy’s alignment to oversight recommendations.\n• \nEnabling a Cultural Shift and Innovation: The National Taxpayer Advocate’s 2019 Annual \nReport to Congress59 recommended that the IRS consider its internal culture and how \na culture shift could better enable the IRS to improve customer service. Revitalizing the \nCommissioner’s reporting structure and the way the IRS internally operates is a large-scale \nattempt at rejuvenating the way we interact and consider how we engage with taxpayers. It \nrequires a massive cultural shift that will ultimately enable better outcomes for taxpayers and \nfacilitate internal innovation across the enterprise.\n• \nElevating Voice of the Taxpayer: In a 2016 Government for the People Report,60 the \nPartnership for Public Service recommended that federal agencies should “consider \nestablishing a chief customer officer who reports to the head of the organization and has \nenough funding and staff to succeed. This could help instill a customer focus and ensure \na single Agency leader has the expertise, insight, authority and responsibility to address \ncomplex customer experience issues that cross Agency divisions or offices.” Additionally, \nthe President’s Management Agenda, CAP Goal #4: Improving Customer Experience with \nFederal Services61 describes what success looks like for a Federal Agency in this area. One \ndescription stated, “\nA modern, streamlined and responsive customer experience means: \nProviding the structure and resources to ensure customer experience is a focal point for \nAgency leadership.” Furthermore, The National Taxpayer Advocate’s 2019 Annual Report \nto Congress62 recommended that the IRS appoint a Chief Customer Experience Officer, \nreporting to the Commissioner or Deputy Commissioner, to unify all taxpayer initiatives \nacross different functions. The Chief Taxpayer Experience Officer, as a direct report to \nthe Commissioner, will be positioned to work across the agency to identify changing \ntaxpayer needs and requirements, and ensure that the taxpayer’s voice is at the forefront of \norganizational strategic planning and decisions. \n59 National Taxpayer Advocate, Annual Report to Congress 2019.\n60 Partnership for Public Service, Government for the People: Profles on the Customer Experience 2016.\n61 2018 President’s Management Agenda, Cap Goal 4, Improving Customer Experience with Federal Services.\n62 National Taxpayer Advocate, Annual Report to Congress 2019.\n63 GAO, GAO-19-157SP\n, High-Risk Series, Substantial Efforts Needed to Achieve Greater Progress on High-Risk Areas.\n", "9.0 \| APPENDIX\n201\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n201\n201\n201\n• \nCoordinated Responses to Key Challenges: A March 2019 GAO report63 focused on high-\nrisk areas across the Federal Government identifed the IRS’s challenges on addressing \nthe tax gap and combating identity theft refund fraud. The report recognizes the agency’s \nwillingness to address these challenges, but mentions we “could do more to identify specifc \nefforts for improving compliance in [our] strategic plan, measure the effects of compliance \nprograms—such as those used for large partnerships—and develop specifc quantitative \ngoals to reduce the tax gap.” As it relates to identity theft refund fraud, GAO mentions we, \n“need to re-establish goals for improving voluntary compliance and develop and document a \nstrategy that outlines how we will use [our] data to help address this issue.” By coordinating \nannual strategic planning with key operational stakeholders to ensure ongoing and new \ninitiatives prioritize addressing these risks the Enterprise Change and Innovation Office will \nhelp mitigate both of these areas, while also keeping the Commissioner informed on \nagency-wide progress.\n• \nIncreased Transparency for Appeals: Establishing an Independent Office of Appeals, and \nthe associated appeals process improvement guidelines written within the TFA, are directly \nin line with the GAO recommendation (in GAO-18-659)64 that the appeals process be more \ntransparent and accessible for taxpayers, specifcally in support of the recommendation \n“Commissioner of Internal Revenue take action to make Appeals customer service standards \nand performance results more transparent to the public.” The Independent Office of Appeals \nwill promote consistency in appeals processes and resolutions, therefore increasing public \nconfdence when engaging with the IRS to address tax compliance issues.\n64 GAO, GAO-18-659, Opportunities Exist to Improve Monitoring and Transparency of Appeal Resolution.\n", "9.0 \| APPENDIX\n202\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n202\n202\n202\n9.7.2 RELATIONSHIPS AND SERVICES DIVISION \n ALIGNMENT TO OVERSIGHT \n RECOMMENDATIONS\nThis Section elaborates on the details of the Relationships and Services Division found in \nSection 6.4 and describes the strategy’s alignment to oversight recommendations.\n• \nSeamless Experience: In December 2019, GAO-20-71 recommended that the IRS \nensure that it collects information on taxpayers’ experiences with all online services \nand the extent to which the services are meeting taxpayers’ needs.65 Divisions explicitly \nresponsible for taxpayer services (e.g., Digital Services Office) will enable a seamless \nexperience for all taxpayers (regardless of taxpayer segment) and ensure that their \ninformation is accurate and available when interacting with agents.\n• \nImprovements in Taxpayer Compliance: GAO-20-55 interviews66 found that responding \nto taxpayer inquiries improves and encourages compliance with the tax code, which can \nreduce the tax gap (the difference between taxes owed and taxes paid). By dedicating \nresources to outreach and education, the IRS would enable improvements in taxpayer \ncompliance and reductions in the tax gap.\n• \nStreamline Operations / Fraud Prevention for Taxpayers: There have been numerous \nreports and guidance put forth from oversight organizations over the last several years \nrelated to taxpayer fraud and identity theft.\n• \nThe Fraud Reduction and Data Analytics Act of 2015 (FRDAA)67 requires federal \nagencies to identify and assess fraud risks in alignment with the GAO Framework for \nManaging Fraud Risks in Federal Programs (GAO Fraud Risk Framework).\n• \nOMB’s Circular No. A-12368 outlines guidance on how agencies should work to \ncombat fraud and preserve integrity within their organizations.\n• \nTIGTA\n’s FY2020 Management & Performance Challenges Report issued guidance \naround identity theft across multiple challenge areas. TIGTA states that it is critical \n“that the IRS has strong authentication controls to ensure the validity of each payer’s \nidentity prior to submission of information returns that are then used for return \nvalidation, compliance matching, and fraud detection purposes.”\n• \nIn January 2020, GAO-20-17469 recommended that the IRS “designate a dedicated \nentity to provide oversight of Agency-wide efforts to detect, prevent, and resolve \nbusiness Identity Theft.” In this report GAO also recommended the Commissioner of \nthe IRS “develop, document and implement a strategy for addressing fraud risks that \nwould be identifed in a fraud risk profle.”\n65 GAO, GAO-20-71 Taxpayer Input Could Strengthen IRS’s Online Services.\n66 GAO, GAO-20-55 IRS Successfully Implemented Tax Law Changes but Needs to Improve Service for Taxpayers with \nLimited-English Profciency.\n67 Fraud Reduction and Data Analytics Act of 2015.\n68 Office of Management and Budget, OMB Circular No. A-123, Management’s Responsibility for Enterprise Risk \nManagement and Internal Control.\n69 GAO, GAO-20-174 Identity Theft: IRS Needs to Better Assess the Risks of Refund Fraud on Business-Related Returns.\n", "9.0 \| APPENDIX\n203\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n203\n203\n203\n9.7.3 COMPLIANCE DIVISION ALIGNMENT \n TO OVERSIGHT RECOMMENDATIONS\nThis Section elaborates on the details of the Compliance Division found in Section 6.5 and \ndescribes the strategy’s alignment to oversight recommendations.\n• \nPromoting Efficiencies / Reducing Fragmentation: The FY2020 TIGTA Management \n& Performance Challenges Report70 and National Taxpayer Advocate’s 2019 Annual \nReport71 highlighted the importance of focusing on ensuring that taxpayers are properly \neducated and understand their fling requirements to avoid unintentional errors and \nnoncompliance. Centralizing exam functions would further develop areas of employee \nexpertise and enable the IRS to identify and track common errors across taxpayer \nsegments. Additionally, this would enable better coordination between taxpayer \nsegments, leading to increased knowledge of relationships and interactions between \ntaxpayers, increased efficiencies throughout exam functions, and a more holistic picture \nof the fnancial enterprise. This knowledge and information would then be used to inform \noutreach and education efforts within the Relationships and Services Division.\n• \nStreamline Compliance Data: In GAO-19-558T,72 in reference to reducing taxpayer \nnoncompliance, GAO recommended “developing and documenting a strategy that \noutlines how IRS will use data to update compliance strategies could help address the \ntax gap.” This recommendation requires dedicated resources to gather, analyze, and use \ndata to update compliance approaches and programs. Chief Compliance Officer would \nwork amongst the existing governance bodies / executive steering committees dedicated \nto furthering the IRS’s ability to leverage data (e.g., Data Analytics Advisory Group, Data \nand Analytics Strategic Integration Board) as well as the Chief Data Officer, to develop \nand improve compliance strategies in a data-driven manner.\n• \nAddress High Income Nonflers: In a May 2020 TIGTA Audit Report,73 TIGTA \nhighlighted concerns related to how the IRS is addressing high-income nonflers, and \nif nonfler strategies and related plans sufficiently include that specifc segment of non-\nflers:\n• \nOne of the specifc recommendations included was to “Consider a reallocation of \nresources in the Collection and Examination functions (along with support from \nCriminal Investigation) to ensure that most, if not all, high-income nonflers are \nsubject to enforcement action.” Through a centralized compliance and enforcement \norganization, the agency will more effectively be able to create and implement \ncompliance strategies that focus on specifc (e.g. high-income) nonfler groups.\n70 TIGTA, Management and Performance Challenges Facing the Internal Revenue Service for Fiscal Year 2020.\n71 National Taxpayer Advocate, Annual Report to Congress 2019.\n72 GAO, GAO-19-558T, Multiple Strategies Are Needed to Reduce Noncompliance.\n73 TIGTA, 2020-30-015, Income Nonflers Owing Billions of Dollars Are Not Being Worked By The Internal Revenue Service. \n", "9.0 \| APPENDIX\n204\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n204\n204\n204\n• \nThis audit also recommended that “more signifcant restructuring and accountability \nis required” in response to a previous recommendation to “designate a senior \nmanagement official with appropriate resources and specifc nonfler duties to \naddress nonfling, including high-income taxpayers and repeat nonflers.” The addition \nof the Chief Compliance Officer addresses this recommendation and provides an \nexecutive who has the resources and authority to effectively design, implement, and \ndrive targeted nonfler strategies.\n9.7.4 ENTERPRISE CHANGE AND INNOVATION \n DIVISION ALIGNMENT TO \n OVERSIGHT RECOMMENDATIONS\nThis Section elaborates on the details of the Enterprise Change and Innovation Division found in \nSection 6.6 and describes the strategy’s alignment to oversight recommendations.\n• \nProtecting Taxpayer Data: The FY2020 TIGTA Management & Performance Challenges \nReport highlighted the importance of ensuring that data within the IRS remains protected \nfrom fraud, third parties, and internal threats. The addition of a Data Office will assist \nin securing threats, preventing unauthorized data disclosure, and ensuring that data \npractices throughout the organization are held to IRS standards. It will also show the \nAgency’s oversight organizations, as well as taxpayers, that the agency is committed to \nprotecting taxpayer data.\n• \nIncreased Data Sharing: According to the 2018 National Taxpayer Advocate Report to \nCongress74, a common theme among the IRS’s ‘Most Serious Problems’ is limited data \nsharing. For example, Most Serious Problem #15, Economic Hardship, specifes that “The \nIRS Does Not Proactively Use Internal Data to Identify Taxpayers at Risk of Economic \nHardship Throughout the Collection Process.” The implementation of a Data Office, and \nan accompanying enterprise-wide data strategy, will help the IRS identify areas in which \ndata could be more proactively utilized or shared to improve taxpayer service.\n• \nEstablishing a “Paper-Free” Environment: There have been numerous pieces of \nguidance put forward from oversight organizations in recent years related to government \nagencies’ necessity to digitize its communication channels with its constituents and \nstreamline digitalization efforts:\n• \nOMB’s M-19-21 guidance75 mandates that by December 31, 2022 all permanent \nfederal records be managed electronically with the appropriate metadata and that \n74 National Taxpayer Advocate, Annual Report to Congress 2018.\n75 OMB, M-19-21, Memorandum For Heads Of Executive Departments And Agencies, Transition to Electronic Records.\n", "9.0 \| APPENDIX\n205\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n205\n205\n205\nafter December 31, 2022, the National Archives and Records Administration (NARA) \nwill no longer accept the transfer of permanent records in analog formats.\n• \nThe 2018 President’s Management Agenda Cross Agency Priority Goals76 \nestablished a long-term vision for modernizing the Federal Government to improve \ndelivery of mission outcomes, provide excellent service, and effectively steward \ntaxpayer dollars on behalf of the American people, including “paperless government” \nas a tool for transformation.\n9.7.5 OPERATIONS MANAGEMENT DIVISION \n ALIGNMENT TO OVERSIGHT \n RECOMMENDATIONS \nThis Section elaborates on details of the Operations Management Division found in Section 6.7 \nand describes the strategy’s alignment to oversight recommendations.\n• \nElevation of Equity, Diversity, and Inclusion: In the 2016 Government-wide Inclusive \nDiversity Strategic Plan,77 the Office of Personnel Management (OPM) stated that one \nof the goals for federal agencies should be to “Diversify the Federal Workforce through \nActive Engagement of Leadership.” More specifcally, OPM recommends that “Leaders \nmust emphasize the importance of inclusive diversity by integrating the value of inclusive \ndiversity within all forms of Agency communications to include social media channels, \nAgency websites, and inter office correspondence. Possible effective communications \nshould be cascaded from senior leadership through to frst line supervision.” By establishing \na dotted-line relationship and consistent communication between the Diversity Office and \nthe Commissioner, the agency is achieving this goal and enabling key messaging about \ndiversity programs and policies to come directly from the Commissioner.\n9.7.6 INFORMATION TECHNOLOGY DIVISION \n ALIGNMENT TO OVERSIGHT \n RECOMMENDATIONS \nThis Section elaborates on details of the Information Technology Division found in Section 6.8 \nand describes the strategy’s alignment to oversight recommendations.\n• \nPromoting Efficiencies / Reducing Fragmentation: TIGTA\n’s October 2019 Report78 on the \nIRS’s most pressing management challenges highlighted “Security Over Taxpayer Data and \nProtection of IRS Resources” as the Agency’s number one challenge. Specifcally, TIGTA \nidentifed challenges related to protecting taxpayer data. The centralized Cybersecurity \n76 Executive Office of the President and President’s Management Council, 2018 President’s Management Agenda. \n77 OPM, Executive Order 13583, Governmentwide Inclusive Diversity Strategic Plan 2016.\n78 TIGTA, Management and Performance Challenges Facing the Internal Revenue Service for Fiscal Year 2020.\n", "9.0 \| APPENDIX\n206\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n206\n206\n206\nOffice within the Technology / Innovation Division will help to address this challenge in that it \ncombines various cyber activities occurring across the Agency that will streamline the IRS’s \nresponse to cybersecurity threats. This hybrid Cybersecurity Office will include technology, \ncyber, and data security, policy and procedures, technical and relational research, as well as \nother facets of cybersecurity program planning.\n• \nSafeguarding Sensitive Personal Data or Information Systems: “Securing IRS systems \nand protecting taxpayer information” will be a top priority of the cybersecurity organization \nwhich is in alignment with the Consolidated Appropriations Act, 2020 (Public Law 116-93).79\n9.7.7 CRIMINAL INVESTIGATION\nThis Section provides additional details to Section 6.5 and the rationale for the reporting \nstructure of Criminal Investigation.\nThe IRS conducted an analysis of our current Criminal Investigation (CI) organizational \nstructure to specifcally evaluate the placement of Criminal Investigation as a direct report to \nthe IRS Commissioner as part of the TFA. During this analysis, we considered the rationale \nfor maintaining the current reporting structure and the rationale for reporting directly to the \nCommissioner. We conducted interviews with CI personnel, including the Chief and Deputy \nChief, stakeholders inside and outside the IRS, and reviewed prior recommendations such as \nthose recommended in the April 1999 Webster Report, “Review of the Internal Revenue Service \nCriminal Investigation Division”\n. Based on our comprehensive analysis, we have determined \nthat transitioning to a structure where the Criminal Investigation Office reports directly to the \nCommissioner would pose challenges and bring additional risk to the agency. Therefore, \nour conclusion is that the Chief of Criminal Investigation should not report directly to the IRS \nCommissioner.\nBackground\nThe Criminal Investigation Office was established in its frst form in 1919 as the Intelligence \nUnit in response to widespread allegations of tax fraud. In 1962, the Congress gave the \nIRS Inspection Service and IRS Criminal Investigation statutory law enforcement authority, \nincluding the authority to execute and serve search and arrest warrants, serve subpoenas and \nsummonses, and to make arrests without warrant for any offense against the United States \nrelating to the Internal Revenue laws. In 1978, the Intelligence Unit changed its name to Criminal \nInvestigation Division (CID) and again changed to Criminal Investigation around 2001. Over \nthe years, Criminal Investigation’s statutory jurisdiction expanded to include money laundering, \nglobal terrorism, and currency violations, in addition to its traditional role in investigating tax \nviolations. Currently, Criminal Investigation resides within Services and Enforcement (S&E) and \nreports to the Deputy Commissioner of Services and Enforcement (DCSE). The DCSE, a Senior \nExecutive Service career position, is a direct report to the IRS Commissioner.\n79 H.R. 1158- Consolidated Appropriations Act, 2020 (Public Law 116-93).\n", "9.0 \| APPENDIX\n207\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n207\n207\n207\nRationale For Maintaining The Existing Reporting Structure\nTransitioning to a structure where the Criminal Investigation Office reports directly to the \nCommissioner would pose challenges and bring additional risk to the agency. These concerns \nare identifed below.\nAssociation with a Political Position\nThe Commissioner role is a presidentially appointed position. The Criminal Investigation \nOffice aligned as a direct report to the Commissioner may create the perception that \nthe Criminal Investigation Office is susceptible to political infuence. Currently, Criminal \nInvestigation reports to the Deputy Commissioner of Services and Enforcement. This \nposition provides the appearance of separation and that Criminal Investigation is given an \nadded layer of protection from political infuence.\nThe IRS is often under public scrutiny given the complex nature of tax legislation. Continued \nreporting to a non-political appointee will help reduce the risk of public perception that the \noutcome of criminal investigations may be politically infuenced. \nFurthermore, as the Commissioner role changes with different administrations, each \nCommissioner may have a different perspective on how to best utilize the capabilities of \nthe Criminal Investigation Office. The fuctuation of Commissioners could potentially mean \nfrequent changes in scope for the unit, ultimately infuencing the unit’s long-term planning \nand ability to achieve its long-term goals. In the organizational structure presented within \nthis report, the Chief of Criminal Investigation will report to the Assistant Commissioner of \nCompliance. As the Assistant Commissioner of Compliance is not subject to change with \neach new administration, they are better positioned to provide additional stability, continuity, \nand long-range strategic planning for the division and the critical compliance programs they \nlead. \nPrivacy of Taxpayer Information\nThe role of the Commissioner requires frequent public engagement with the Congress and \nother external stakeholders, during which they are required to speak on behalf of the agency. \nHaving the Criminal Investigation Office as a direct report could place the Commissioner \nin a delicate position when speaking publicly, especially if faced directly with questions \nconcerning sensitive or protected taxpayer information. The Assistant Commissioner \nof Compliance provides an additional layer of security to protect sensitive information \nand insulate the Commissioner from potentially difficult legal entanglements, while still \nallowing for the communication of key risks, challenge areas and progress of the Criminal \nInvestigation Office.\n", "9.0 \| APPENDIX\n208\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n208\n208\n208\nCommissioner Bandwidth \nIn our proposed organizational structure, the Commissioner has ten direct reports, \nwhich includes Counsel, Taxpayer Advocate Service, Independent Office of Appeals, \nCommunications, Enterprise Change and Innovation, Taxpayer Experience, Operations \nManagement, Information Technology, Compliance and Relationships and Services. \nThe operational bandwidth of the Commissioner is naturally limited due to the external \nobligations required by the office (e.g., frequent public-facing hearings, testimonies, speaking \nengagements, and other external events) in addition to presiding over the nation’s tax \nadministration. \nIn our proposed structure, the Criminal Investigation Office would report to the Assistant \nCommissioner of Compliance. In this structure, the Assistant Commissioner of Compliance \nwould have greater bandwidth to focus on and accommodate the needs of Criminal \nInvestigation. Having an executive that oversees all enforcement activities, both civil and \ncriminal, allows for a more integrated and comprehensive compliance strategy. This also \nallows for a more balanced perspective on the agency’s enforcement challenges and allows \nfor more effective prioritization and communication of key issues to the Commissioner or \nother senior executives. It also allows for the appropriate level of focus and jurisdiction \nwithout the potential for undue political pressure or marginalization. This executive \nposition would facilitate additional collaboration and integration between the enforcement \norganizations within the agency.\nLastly, as an agency we respond to many legislative mandates, seemingly annually (e.g., \nCoronavirus Aid, Relief, and Economic Security (CARES) Act; Tax Cuts and Jobs Act \n(TCJA)). The likelihood that the Commissioner would need to focus attention on these \nactivities versus the daily activities of the Criminal Investigation function is high. Having \nCriminal Investigation reporting to the Assistant Commissioner of Compliance would help \nensure additional attention is paid to the unit. If the Commissioner would need to prioritize \nother services or initiatives due to extenuating circumstances, reporting to the Assistant \nCommissioner of Compliance would allow for the appropriate emphasis and focus on \nCriminal Investigation operations.\n", "9.0 \| APPENDIX\n209\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n209\n209\n209\nCollaboration\nOne factor of the Criminal Investigation Office’s success is the ability to work with the other \nbusiness units. Maintaining the same reporting level as the other business units encourages \nand allows for stronger working relationships and a faster transfer of information. Currently, \nreporting to the Deputy Commissioner for Services and Enforcement enables the Criminal \nInvestigation Office to effectively work across each of the business units to gather necessary \ninformation or receive referrals on cases without coordinating through an additional \nexecutive. The Criminal Investigation Office’s current placement at the business unit level \nencourages open and candid communication with the other organizations across the agency \nbecause by appearances they are all on the same level.\nWhile an open line of communication between the Criminal Investigation Office and the \nCommissioner is undoubtedly important, it is achieved by the current monthly and/or quarterly \nmeetings in addition to all ad hoc meeting requests made. As a direct report to the IRS \nCommissioner, there is a risk that the Criminal Investigation Office could wield undue infuence \nover the other IRS compliance operations. Therefore, the Criminal Investigation Office and \nother IRS compliance programs will benefit from reporting to aO Assistant Commissioner. \nA major focus for IRS criminal investigators over the past several years has been cases \ninvolving international tax enforcement, employment tax, tax refund fraud and tax-related \nidentity theft. As fnancial crimes have evolved and proliferated around the world, so have the \nIRS Criminal Investigation Office special agents and their abilities to track the proceeds of \nfnancial crimes. The IRS has been instrumental in investigating instances of public corruption, \ncybercrime, terrorist fnancing and money laundering. Housing the Criminal Investigation Office \nwithin the Compliance Division will allow the office to continue to do the very important and \nhigh-profle work associated with cross-jurisdictional cases related to money-laundering, human \ntrafficking, and global terrorism. It will also allow for efficient administration of the Criminal \nInvestigation Office programs and to emphasize the office’s primary goals of compliance \nstrategy and enforcement oversight while formulating a joint compliance strategy for the agency. \nWhile the TFAO and current Criminal Investigation leadership considered the rationale for both \nmaintaining a similar reporting structure to the current structure and reporting directly to the \nCommissioner, ultimately, we determined that the Criminal Investigation Office should not report \ndirectly to the Commissioner. In our proposed structural reorganization for the agency, the Chief \nof Criminal Investigations will report to the Assistant Commissioner of Compliance. \n", "9.0 \| APPENDIX\n210\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n210\n210\n210\n9.7.8 CYBERSECURITY\nThis Section provides additional details to Section 6.8 and the rationale for the reporting \nstructure of the Cybersecurity Office. \nCybercrime impacts companies in the United States and internationally daily. Over the past \nseveral years, the IRS has taken measures to anticipate cyber threats, strengthen and enhance \nour defenses, improve our technology infrastructure, improve our governance and accountability \nand collaborate with external stakeholders to share information regarding potential threats, \nfraud, and identity theft. These efforts yielded impressive results; however, there is more to do. \nThe cyber landscape constantly evolves, and we continue to experience increasingly frequent \nand sophisticated efforts by cybercriminals to steal taxpayer data, fle fraudulent refunds, and \ninfltrate our systems.\nTo determine how best to position IRS to combat cybersecurity threats, a thorough examination \nof our current cybersecurity operations was completed. Key stakeholders were interviewed in \nthe areas of cybersecurity, fraud, and identity theft. We also examined the FY2020-FY2022 IT \nSecurity Program Plan, which focused on key aspects of our current and future cybersecurity \nlandscape. Further, we reviewed the Cybersecurity Five-Year Strategic Plan, IRS Strategic Plan \nand IT Modernization Plan. We also reviewed operational models of other organizations (e.g. \nDepartment of Agriculture, Energy Sector, State Departments of Revenue), evaluated industry \nresearch from academia (Carnegie Mellon University) and inputs from IRS subject \nmatter experts.\nIn our research, we sought to determine the most effective alignment for our agency to make \ncontinual improvement. There are varying schools of thought around the most effective approach \nfor cyber organizations. Some research indicates that 54% of senior information security leaders \nreport directly to CIO/IT Executive.80 This role cannot be done by a technology professional with \ntechnology training alone. In-house IT professionals spend most of their time managing their \nnetwork and driving new solutions for the business, leaving very little time for security – which \nrequires its own set of niche skills. A review of research conducted at Carnegie Mellon University \ninvolving an examination of the cyber intelligence practices of 30 organizations (6 from \ngovernment and 24 from industry), also provided information specifcally around their strategic \napproaches to cyber intelligence, focused on identifying the methodologies, processes, tools \nand training that shaped how organizations assessed and analyzed cyber threats. Info-Security \nmagazine indicates that traditionally, the cybersecurity function within a business sat in the IT \nteam, overseen by a Chief Technology Officer or Chief Information Officer. Now, as businesses \nreact to these changes in the digital landscape - broadly known as digital transformation - we’re \nseeing a fatter style of cybersecurity team. Businesses are hiring employees that specialize \n80 Gartner, Survey Analysis: IOfoSmation Security Governance.\n", "9.0 \| APPENDIX\n211\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n211\n211\n211\nin the different types of security which refect the ever-increasing ways businesses connect \nto the online world. In tandem, they are seeking employees to effectively operate in the cyber \nenvironment that can lead from both a strategic standpoint, as well as being able to understand \nthe technical side of security as an enterprise. \nUnder the current IRS structure, Cybersecurity falls under the Chief Information Officer \n(CIO) and the Chief Information Security Officer (CISO). The Federal Information Security \nModernization Act of 2014 (FISMA) states under § 3554 the head of each agency shall be \nresponsible for:\nA. Providing information security protections commensurate with the risk and magnitude of \nthe harm resulting from unauthorized access, use, disclosure, disruption, modifcation, or \ndestruction of—\n• \ninformation collected or maintained by or on behalf of the agency; and\n• \ninformation systems used or operated by an agency by a contractor or other \n organization on behalf of an agency\nB. Ensuring that information security management processes are integrated with agency \nstrategic, operational, and budgetary planning processes.\nIn general, the CIO has the authority to ensure compliance with the requirements imposed \non the Agency under FISMA. The CIO has a legislative mandate to maintain and improve the \nsecurity of their agency’s information and information systems. IRS’s current internal policies \ndelegate management of the agency’s information to the CIO. Under FISMA, the CIO delegates \ntasks related to information security to the senior agency information security officer (often \nreferred to as CISO). \nUnder this structure, we have been successful in performing security functions and governance \nat the organizational level. Our cybersecurity units protect our systems and data, while \ncontinuing to advance capabilities to defend the agency against cyber-attacks from nation \nstates, cyber criminals, cyber activists and hacktivists. Cybersecurity also protects IRS assets \n(technology, information and people) from theft, malicious damage to hardware, software \nand electronic data security. The agency has continued to enhance cybersecurity monitoring \nand data protection capabilities. We have implemented layered controls and established an \nincident response capability that performs around-the-clock intrusion and fraud analytics to \nidentify, respond to, and mitigate emerging threats or fraudulent access/transactions. Cyber \nalso monitors the IRS enterprise to proactively identify possible insider threats and take \naction against confrmed threats. This serves to protect the IRS from threats and attacks while \nmaintaining necessary information availability, confdentiality, and integrity so that we can \ncontinue to serve the people of the United States. Although we have made great strides in \ncybersecurity, we can continue to improve. Because cyber is currently under the direction of \nthe Chief Information Officer, as identifed in our research, many times, this creates a structure \nwhere the information technology and systemic infrastructure work has a strong focus. With \n", "9.0 \| APPENDIX\n212\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n212\n212\n212\nsmaller staffs, this sometimes leaves less time to focus on incoming intelligence, data sharing, \nor emerging trends and threats that require more analytical or operational research and action. \nIn addition, Direct Hire Authority for cybersecurity positions remains available, but due to hiring \nconstraints, the IRS cannot sustain or grow its cybersecurity workforce. \nIn the future, the Assistant Commissioner Chief Information Officer, as a direct report to the \nCommissioner, will refocus the expectations of the Cyber Office to strengthen our ability to \naddress fraud risks and utilize fraud data, while ensuring that the agency infrastructure and \ndigital technology are strong. Strengthening relationships with the operating divisions will \nallow for more effective and timely utilization of information to reduce redundancies. This \nwill serve to provide IRS employees and taxpayers with the necessary systemic solutions to \neffectively manage tax administration. A reimagined strategy will help to reduce redundancies \nin identifcation and treatment of cyber incidents, improve efficiency, streamline data sharing \nand treatment, and improve agency-wide oversight of cyber incidents from an operational and \ntechnological perspective.\nThe Information Technology Division through the Cybersecurity Office will ensure that systemic \nsolutions to protect data are tightly integrated across all aspects of the agency from systems and \ntechnology to operations and data sharing. Fully staffing with a diversely skilled, multi-talented, \nand effective workforce that can address the technical and operational aspects of cyber security \nwill be crucial to continued success in the rapidly evolving landscape.\nBased on our extensive research, we will take a holistic approach and continue to refne and \nexpand plans outlined in the FY2020-2022 IT Security Program Plan. This approach must be \ncombined with a vigilant dedication to continuously evolving and developing new methods to \nstay ahead of the cyber attackers. We will ensure that any gaps that create duplicative processes \nor inefficiencies are adequately addressed in the Information Technology Division. \nThe Cybersecurity Office will work closely with the Data Office and operating divisions to \ncontinue to effectively realize the cyber goals identifed in the plan:\n• \nGoal 1: IRS uses security to be a trusted business enabler\n• \nGoal 2: IRS has a world class cybersecurity workforce\n• \nGoal 3: IRS drives security innovation throughout the enterprise\n• \nGoal 4: IRS has full visibility and control of its security delivery lifecycle\n• \nGoal 5: IRS has accurate threat vulnerability and impact insights through its security \necosystem\n• \nGoal 6: IRS makes risk-informed, data driven security decisions and proactively prevents \nincidents\nUltimately, we want to have the strongest, most effective, and agile organization to move \nus into the next decade. Regardless of structure, our governance bodies, working groups, \n", "9.0 \| APPENDIX\n213\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n213\n213\n213\ncross-functional teams, and information sharing processes must be designed to ensure that \nInformation Technology, cyber security, and Business Units are aligned and in lock-step to \ncombat cyber threats. This will be accomplished through consistent monitoring of suspicious \nbehavior, clear communications, effective technology, cross-organization collaboration, essential \ndata sharing, and policy adherence across the Agency and with stakeholders. \nMoreover, with the continuous disruption of emerging technologies, cyber criminals never rest. \nIn alignment with the TFA and the strategies outlined for the Taxpayer Experience, Training, and \nthe Organizational Redesign Strategies, we must continue to evolve. To streamline our cyber \napproach, reduce duplication of efforts, ensure appropriate level of oversight, and address \nemerging concerns, we must continue to have an Agency-wide, proactive approach. Due to the \nspread of sophisticated threats and the sensitive taxpayer information contained in our systems \nwe plan to ensure that we continuously seek cutting edge information and tools. Our approach \nincludes technology, cyber and data security, policy and procedures, technical and relational \nresearch, as well as other facets of cyber security program planning. We know that cybersecurity \nteam members need to have clear lines of communication to key business executives, with \nstandardized ways of presenting data. They need expanded access to business support \napplications, analysis tools, data repositories, analysts and more.\nInvestment in additional tools, technology, and processes is necessary to defend against cyber \nthreats and stay current with changing National Institute of Standards and Technology (NIST) \nguidelines. These NIST guidelines are intended to guide how federal agencies implement digital \nidentity services, along with how potential fraud, security, user and customer experience are \naddressed, which are key components of overall cyber operations. A reimagined focus on these \ncyber activities will allow the IRS to continuously strengthen our cyber position. Refocusing IT \ncybersecurity initiatives to provide a single point of coordination with a clear mission from which \nIRS mitigates risk in an organized and efficient manner is key. It will further help to ensure the \nentire Agency is prepared, well informed, and knowledgeable about cyber activities and any \noperational impacts.\nMoving forward, we will remain vigilant on the fundamentals of cyber security including malware \noutbreaks, data breaches, and protection of IRS systems and data. Continuing to advance our \ncapabilities to defend the Agency against cyber-attacks from cyber criminals, cyber activists and \nhackers. Active defense of IRS’s information and systems are key to successfully meeting the \nTFA objectives.\n", "9.0 \| APPENDIX\n214\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n214\n214\n214\n9.7.9 POLICY AND LEGISLATION\nThis Section outlines recommendations for policy and legislation aligned to our Organizational \nRedesign Strategy in Section 6.0.\nBackground\nThe IRS took steps to identify policy and legislation recommendations necessary for successful \nexecution of the TFA strategies. Currently, there are aspects of current policies and laws that \nconstrain the IRS’s ability to deliver the best possible taxpayer experience.\n To assess the current state and provide recommendations, we took the following steps: \n• \nReviewed current processes for implementing policies, guidance, and legislation\n• \nIdentifed best practices for future implementation of legislative changes\n• \nIdentifed legislative changes necessary to support the organizational redesign, taxpayer \nexperience, training and IT strategies \n• \nReviewed prior legislative recommendations by the IRS and the National Taxpayer \nAdvocate (NTA) that may support or impact the strategies developed as part of the TFA\nBased on the current state assessment, included within this Section are the policy and \nlegislative recommendations that will enable us to successfully implement all components \nincluded within the TFA strategies.\nRecommended Legislative Changes\nLegislative requirements set out standards, procedures, and principles that must be followed and \nguide the development of internal policy. Provisions or components within legislation may impact \ntaxpayer interactions and challenge IRS efficiency.\nThe FY2021 President’s Budget proposed the following legislative priorities to improve tax \nadministration and taxpayer service: \n• \nProvide the IRS with greater fexibility to address correctable errors - the proposal makes \nit easier for the IRS to correct clear taxpayer errors, directly improving tax compliance and \nreducing EITC and other improper payments, and freeing IRS resources for higher-valued \nenforcement activities.\n• \nIncrease oversight of paid tax return preparers - to promote high-quality services from paid \ntax return preparers, the proposal would explicitly provide the Secretary of the Treasury with \nthe authority to regulate all paid tax return preparers.\n• \nImprove clarity of worker classifcation and information reporting requirements - the proposal \nincreases clarity in the tax code, reduces costly litigation, and improves tax compliance.\n", "9.0 \| APPENDIX\n215\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n215\n215\n215\nThe following two proposals would enhance the IRS’s enforcement programs and make IRS \noperations more efficient, and its program spending more transparent:\n• \nAuthorize a Program Integrity Cap adjustment as proposed in the FY2021 President’s \nBudget.\n• \nAllows the Financial Services and General Government Subcommittee to appropriate \nadditional funds beyond their 302(b) allocation for enforcement activities that will \nhave a net positive return on investment for the government.\n• \nWould generate $4.6 billion in revenue per year once new hires are fully trained, with \na return on investment of $1 to $8.\n• \nEstablish IRS Centralized Services. \n• \nThis proposal expands on the Nonrecurring Expenses Fund proposed in the FY2021 \nPresident’s Budget.\n• \nNearly 100% of Operations Support expenses would be paid for through the IRS \nCentralized Services.\n• \nExpenses initially would be budgeted as a component of an IRS program based \non employee square footage occupancy by building. During the budget year, the \nexpenses would move to the IRS Centralized Services for execution.\n• \nIncreased transparency of the full cost of IRS programs would create incentives for \nefficiencies and allow for self-funding of special projects as well as other centralized \nshared services and technology.\n9.7.10 EXTERNAL OVERSIGHT AND ADVISORY\nAs part of conducting activities related to optimizing our organizational structure, we also identi-\nfed recommendations for achieving additional benefts while working with our external oversight \nand advisory organizations. These partnerships are critical in our ability to effectively provide us \nwith an objective point of view on how well we are executing on our mission and meeting the \nneeds of taxpayers.\nOverall, the IRS receives substantial oversight and guidance from several federal organizations, \nexternal committees and advisory boards (a comprehensive list of these organizations and more \ndetail about how we work with them is provided in Appendix 9.7\n.0). Despite the benefts gained \nfrom receiving guidance from these partners, the IRS is faced with numerous challenges as part \nof interaction with these organizations (e.g., signifcant fnancial costs, dedicated work hours \nresponding to corrective actions).\n", "9.0 \| APPENDIX\n216\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n216\n216\n216\nCoordination Across Oversight Entities:\nThe Taxpayer Advocate Service (TAS) and external advisory boards, such as Electronic Tax \nAdministration Advisory Committee (ETAAC) and Internal Revenue Service Advisory Council \n(IRSAC), help highlight process improvements and opportunities for administrative tax policy \nenhancements. The National Taxpayer Advocate (NTA) provides an Annual Report to Congress \nthat features the ten most serious problems encountered by taxpayers. The IRS provides a \nresponse to the Annual Report. Although there is not a direct relationship between the most \nserious problems highlighted by TAS and the subject of TIGTA and GAO audits, they are \nindirectly related in the types of IRS processes and programs we need to improve. \nOverall, the IRS welcomes input from our oversight and advisory partners and recommends \nthat this input is better coordinated, both internally by the IRS and externally by our partners. \nWe recommend that our partners collaborate more to leverage each other’s pre-existing work \nand avoid opening audits or other engagements where another body is already engaged. \nWe invite oversight bodies to provide practical recommendations acknowledging holistic \nresource allocations – but we often receive multiple, competing recommendations that the \nIRS should simply allocate more resources to specifc programs, which are not helpful. \nWithout acknowledging in each report the difficult task of allocating limited resources, the \nrecommendations present an unrealistic picture of the issue and oversimplify its possible \nsolution. This misleads both the public and policy makers into possibly believing that such \ncompliance and enforcement issues can be easily resolved. We are committed to leveraging the \npositive aspects the oversight bodies and advisory committees provide and intend to continue \nto work with these groups to identify process efficiencies during implementation of the Taxpayer \nExperience Strategy, Organizational Redesign Strategy, and Training Strategy. We suggest that \nGAO conduct an annual audit of TFA strategy execution to provide oversight and an objective \nview of our progress during implementation.\n9.7.11 GOVERNANCE\nThis Section outlines governance recommendations aligned to our Organizational Redesign \nStrategy in Section 6.0.\nThroughout our research phase we identifed non-structural components of an organization that \nenable efficient and agile operations. Recognizing that effective governance is a key factor for \norganizational change, we conducted an internal analysis of our current governance processes \nto identify areas for improved decision-making. Our analysis consisted of internal reviews of \ngovernance documentation (e.g., governance board charters) and interviews with members of \nour Senior Leadership Team, which serves as the overarching advisory body for the IRS. Our \nfndings indicated there are four main areas for improvement within the current governance \nprocess.\n", "9.0 \| APPENDIX\n217\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n217\n217\n217\nCurrent State Challenges and Opportunities\nOur analysis of current governance processes revealed the following challenges and \nopportunities related to agency-wide decision-making.\n•\nAccountability: Improve clarity of decision-making to support success of key strategic \nand innovative projects.\n•\nPrioritization: Enhance identification and allocation of resources to enterprise-wide \npriorities and improve communication at both the senior executive level and lower levels \nof leadership.\n•\nGovernance Structure: Refine the size and number of governance organizations to \nreduce bottlenecks and can slow down decision making. The current structure consists of \nnumerous governing boards and committees, some of which consist of 50+ members.\n•\nProcesses and Transparency: Standardize decision-making processes across \ngoverning committees to clarify how and when decisions should be made. Ensure \ndecision-making authority is clearly identified across governing tiers. UtJlize forums for \ndeciding upon key issues rather than for information-sharing.\nRecognizing these challenges, we have made progress in recent years to standardize our \napproach for organizational governance and streamline our governance boards. Our governance \nmaintenance process, signed by the Deputy Commissioner for Services and Enforcement \n(DCSE), the Deputy Commissioner for Operations Support (DCOS), and the IRS Chief of Staff \nin early 2018, defnes a process for governance standardization, chartering, and implementation \nof best practices. Additionally, we have reduced our intra-agency governance boards and ESCs \nfrom over 140 in FY2018 to under 70. Governance liaisons within each business unit also work \nto ensure boards are active and continuously review their charters.\nWe have also made progress in recent years related to furthering our ability to effectively \nprioritize enterprise-wide decisions, specifcally related to our broader organizational goals \noutlined within the FY2018-FY2022 IRS Strategic Plan. In FY2019, IRS leadership across the \nagency discussed their shared goals, objectives, and key projects. From these discussions, the \nleadership team developed a series of agency-wide priorities aligned to each of the Strategic \nPlan’s goals and objectives. A strong foundational governance and communication model was \nnecessary to execute upon this effort and its successful implementation highlights how we \ncontinue to refne our governance process.\nRegardless of these recent achievements over the last several years, we will continue to \nimprove. We recognize there is tremendous value in conducting additional activities related to \nour governance procedures and these will continue to occur over the coming months to ensure \na successful implementation of the strategies outlined within this report as well as the way we \nprioritize projects that span the enterprise. \nAn initial summary list of activities on how we will continue to improve upon our governance are \ndescribed below and will continue to be developed and iterated upon in the future. \n", "9.0 \| APPENDIX\n218\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n218\n218\n218\nAccountability Recommendations\nLeadership accountability will play a role in the effective administration of the strategies outlined \nwithin this report. Additionally, improved transparency innately fosters an environment of \naccountability. Clearly communicating and documenting decisions will enable all stakeholders to \nmaintain awareness of current operations, accountable parties, and agency decisions.\nImprovements are required from the top down and the governance structure must refect that. \nTherefore, the current Senior Leadership Team must be reformed and re-tasked as the smaller \nand more effective governing body. The Senior Leadership Team will be compromised solely of \nCommissioner direct reports. This much smaller governing body will direct all Executive Steering \nCommittees (ESC) with documented decisions and assigned responsibilities and commitments. \nIt will also provide a clear escalation path for cross-functional governance boards and settle \ndisputes between organizations. The Commissioner will have fnal say in decision making. If the \nCommissioner disagrees with the majority of the board, that vote will be documented, but the \nCommissioner will still have the authority to direct subordinate ESCs and direct reports. \nGovernance Prioritization Recommendations\nWe also commit to institutionalizing an intermediary, to help reconcile and manage priorities, \nallocate budget and escalate cross-functional issues to the Deputy Commissioner or the \nCommissioner. This function will sit within the Enterprise Change and Innovation Division, \nand will focus on transparency, accountability, communication, and the prioritization of all key \nenterprise initiatives. This office will also continue the maintenance and knowledge management \nefforts currently carried out in the CFO’s Office of Strategic Planning. \nOur current governance structure is divided among two distinct tiers – top level governing \nboards and business / functional boards. These two tiers differ in the amount of responsibility \nand level of impact their decisions have on Service-wide issues. The current governance \nmaintenance process does not outline how issues should be elevated from a business/functional \nboard to a top-level governing board. Moving forward we will defne a clear escalation path and \nwill outline the conditions in which decisions can be made at lower tiers. \nGovernance Structure Recommendations\nUsing our governance maintenance process, we will continue to review the number and size of \nour governance boards. While many of our governance boards have a unique and important role \nin the implementation of our mission, we discovered that there is not a concerted effort to ensure \nconsistent application, and that the IRS governance structure should be designed to ensure the \nbasic functions of the IRS are holistically addressed. \n", "9.0 \| APPENDIX\n219\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n219\n219\n219\nFor example, the Filing Season Readiness Executive Steering Committee (ESC) manages \nthe enterprise-wide preparation for the annual fling season, consisting of over 33 standing \norganizations and members, as well as an additional 14 ad-hoc organizations and members. \nThis Governance Board is a strong indicator of how cross-organizational governance can be \nsuccessful (this ESC currently consists of members from both DCSE and DCOS). While the \nFiling Season Readiness ESC meets critically important objectives each year to prepare for \neach Filing Season, its authority ends with the start of Filing Season and the IRS moves back \nto siloed and parochial management of Filing Season. The IRS needs an ESC that continues to \nmanage Filing Season, not just the preparation for Filing Season. There is no effective or clear \nescalation path that addresses the concerns of all stakeholders in the most critical function and \ntime period of the IRS. Effective governance is needed to support any organizational structure. \n \nThe Senior Leadership Team will approve a redesigned IRS governance structure within one \nyear of submission of this report. Furthermore, the Senior Leadership Team will also approve the \naddition or removal of future governance boards. This change will ensure that IRS governance, \nonce modernized, will remain focused on delivering the goals of the Agency while minimizing \nredundancies, unnecessary levels of management, and ensure all cross functional operations \naddress all stakeholders are managed with effective governance. \nGovernance Process and Transparency Recommendations\nAs part of our research, we found that in some cases, decisions made in various governance \nand executive steering committee forums were not clearly and consistently documented and \ncommunicated. Consistent governance will create standardization and clear guidelines. Moving \nforward, we plan to emphasize consistent documentation and communication of decisions – and \nthe basis for decisions – throughout the Agency. \nCurrently, our Governance Virtual Library houses documentation related to governing body \ncharters, governance best practices, and business unit governance points of contact. In order \nto improve transparency, we will use this electronic medium to house key decision-making \ndocumentation such as meeting notes, agendas, and key decision points themselves. \nIn reviewing our Governance Virtual Library we analyzed the charters, mission statements, and \nscopes of work of the 68 currently established IRS governance boards. Our fndings concluded \nthat many governance boards work on tasks that may overlap with other boards, resulting in \nduplicative efforts or misalignment in certain focus areas (e.g., data management, fnancial \nmanagement, human capital). We believe there could be opportunities to optimize efficiencies \nthrough consolidating and reviewing these governance boards to minimize duplicative efforts \nacross the agency. \nThrough our interviews we also discovered that many of our governance boards operate \nprimarily as information-sharing sessions as opposed to decision-making forums. While \ninformation sharing plays an important role, the purpose of top-level governance boards is to be \n", "9.0 \| APPENDIX\n220\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n220\n220\n220\neither advisory or decisional. Considering this, we will aim to make future governance boards \nfocused on topics requiring input or decisions. Furthermore, we will institute a standardized \nvoting process for key decisions or recommendations within all governance boards and ESCs \nin order to help clarify how decisions are made and ensure a uniform approach to all Agency \ndecisions. We will also emphasize the importance of escalating and documenting decisions \nthrough our defned governing bodies to ensure consistent decision making.\nLastly, we commit to reaching decision points through clearly identifed roles and responsibilities \nacross our governing bodies. Moving forward, governing body members will know who is \nresponsible for making fnal decisions versus those that assume an advisory role through \nclearly defned charters and outlined chairs. In addition, structured, pre-set agendas and active \nfacilitation from key decision-makers will be essential in ensuring prompt decision-making. \n9.7.12 CURRENT TO FUTURE \n ORGANIZATIONAL \n STRUCTURE CROSSWALK\nThe TFAO developed a crosswalk of the current and future structure of the IRS offices. This \nis not a comprehensive list of offices and may change as we dive deeper into the detailed \norganizational chart and operating model.\n", "9.0 \| APPENDIX\n221\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n221\n221\n221\n9.8 FUNDING ALIGNMENT\nThis Section addresses inconsistencies between the current IRS funding structure and the \nproposed future organizational structure.\n9.8.1 NEW APPROPRIATIONS STRUCTURE\nThis report recommends the authorization of an IRS Centralized Services (ICS) fund. To \nillustrate approximate funding levels, the following table allocates the FY2020 enacted budget \nacross the existing appropriations accounts and the newly proposed fund.\nIllustrative Centralized Service\nAllocation using FY2020 \n(non-supplemental) \nAppropriations levels\nMillions of Dollars\nFY2020 Enacted\nNotional Budget\nICS Allocation\nAs Executed\nTaxpayer Services\n2,512\n4,763\n(1,961)\n2,832\nEnforcement\n5,010\n6,468\n(1,945) \n4,523\nOperations Support\n3,808\n69\n(15)\n53\nIRS Centralized Services\nna\n3,921\n3,921\nBusiness System \nModernization\n180\n180\n180\nTotals\n$11,510\n$11,510\n-\n$11,510\n", "9.0 \| APPENDIX\n222\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n222\n222\n222\nAs the example illustrates, the Taxpayer Services, Enforcement, and Operations Support \naccounts would pay for the direct costs of mission activities and, via a cost allocation, pay for the \ncentralized services necessary to support them. \nThe proposed structure provides several immediate benefts. With the Taxpayer First Act, the \nCongress directed the IRS to reorient itself to be more taxpayer-focused. The reorganization \nand attendant fnancial restructuring implements that direction. It provides the Congress and the \nAdministration a clear view of how appropriations fund major IRS activities, including support \nactivities. Using the IRS Centralized Services fund also encourages IRS operating units to \nbecome more efficient with their use of support services because they would have to pay for \nmore costly support from their own funds and conversely would accrue the beneft of cost \nsavings. \nBasic IRS operations increasingly rely on information technology and innovation. The proposal \nidentifes these key areas as activities in the allocation fund. Placing them in the fund would \nallow operating units to apply technology solutions to problems as they emerge, even if the \nfunding had not been included in the initial allocation. \nThe ICS would be a revolving fund modeled on the General Service Administration’s Working \nCapital Fund. Like the GSA’s fund, it would be funded solely by its customers and not require \ndirect appropriations. It would centralize the funding of a wide range of support activities, most \nof which are currently funded in the Operations Support appropriation. The IRS proposes \nauthorizing legislation that would allow the allocation fund to be available for technology and \nother centralized services. Customer agreements between the operating units would dictate \nservice levels in exchange for funding allocations. \nThe IRS would allocate costs using simple methods such as FTEs, direct usage, budget dollars \nmanaged, etc. For example, for facilities costs, the IRS would use a model of employee square \nfootage occupancy by building, allowing for precise accounting of facility costs by fnancial \nplan. The frst year of the fund, the IRS would baseline cost allocations. After the “baseline” \nyear, changes in later years – beyond infationary increases – would be the responsibility of the \nbusiness unit, which would bear the cost of increases and beneft from any savings achieved. \nBy embedding support costs within the program budget activities, the proposal creates visible \nincentives for business units to reduce support expenses. The allocation fund also provides a \nmechanism for business units to self-fund critical projects that emerge after the budgets were \nset, subject to established standards. \n", "9.0 \| APPENDIX\n223\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service \| Taxpayer First Act\n223\n223\n223\n9.8.2 ORGANIZATIONAL ALLOCATION OF FUNDING\nTo illustrate funding levels, the table below allocates the FY2020 enacted budget across the \nproposed organizational structure. It approximates the fund allocation by using a simple FTE-\nbased approach. As IRS implementation of the Taxpayer First Act continues and cost attribution \nestimates become more refned, a re-examination of the IRS appropriation account structure \nshould also be considered.\nIllustrative Allocation of FY2020 Funding By Proposed Business\nFunctions\nMillions of Dollars\nGross Funding\nICS Cost \nAllocation\nFunding Levels\nTaxpayer Services\n3,423\n(1,362)\n2,061\nSubmission Processing\n1,039\n(498)\n541\nNational Taxpayer Advocate\n332\n(102)\n230\nTaxpayer Services\n4,793\n(1,961)\n2,832\nExamination & Determinations\n3,985\n(1,218)\n2,767\nCriminal Investigation\n829\n(183)\n647\nCollection\n945\n(355)\n589\nAppeals\n253\n(80)\n173\nChief Counsel\n456\n(109)\n347\nEnforcement and Compliance\n6,468\n(1,945)\n4,523\nOffice of the Commissioner\n69\n(15)\n53\nCIO\n-\n2,078\n2,078\nFacilities\n-\n882\n882\nFacilities Management\n-\n120\n120\nHuman Capital Organization\n-\n294\n294\nEnterprise Change and Innovation\n-\n161\n161\nChief Financial Officer\n-\n68\n68\nProcurement\n-\n66\n66\nCommunications\n-\n28\n28\nPrinting, Postage and Other Shared \nServices\n-\n226\n226\nIRS Centralized Services\n-\n3,921\n3,921\nBusiness System Modernization\n180\n180\nTotals\n$11,510\n-\n$11,510\n", "S E C T I O N10\nInternal Revenue Service \| Taxpayer First Act \nBIBLIOGRAPHY\nInternal Revenue Service \| Taxpayer First Act \nThe Bibliography Section includes documents used to develop the Taxpayer \nExperience, Training and Organizational Redesign Strategies such as \noversight reports, testimonies and recommendations, customer satisfaction \nsurvey results, publications, studies, briefngs and statutes.\n10.1 OVERSIGHT REPORTS, \n TESTIMONIES AND RECOMMENDATIONS\nGeorge, J. Russell. (2018). Joint Hearing Before the Committee on Oversight and Government \nReform, Subcommittee on Health Care, Benefits and Administrative Rules and \nSubcommittee on Government Operations U.S. House of Representatives: Continued \nOversight of the Internal Revenue Service. Washington D.C.: Treasury Inspector General for \nTax Administration\nGeorge, J. Russell. (2017). Hearing Before the Committee on Appropriations, Subcommittee \non Financial Services and General Government United States Senate: Review of the \nPresident’s Fiscal Year 2018 Funding Request for the Internal Revenue Service. Washington \nD.C.: Treasury Inspector General for Tax Administration\nMartin, Russell P\n. (2017). Joint Hearing Before the Committee on Oversight and Government \nReform, Subcommittee on Health Care, Benefts and Administrative Rules and \nSubcommittee on Government Operations U.S. House of Representatives: Examining the \nIRS’s Customer Service Challenges. Washington D.C.: Treasury Inspector General for Tax \nAdministration\n", "225\nInternal Revenue Service \| Taxpayer First Act\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n225\nInternal Revenue Service \| Taxpayer First Act \nMcTigue, Jr., James R. (2018). Tax Administration: Status of IRS Future State Vision. GAO-19-\n108R. Washington, D.C.: United States Government Accountability Office\nMihm, J. Christopher. (2019). Priority Open Recommendations: Internal Revenue Service. GAO-\n19-324SP\n. Washington, D.C.: United States Government Accountability Office\nNational Taxpayer Advocate. (2020). Annual Report to Congress 2019. Washington, D.C.: \nTaxpayer Advocate Service\nNational Taxpayer Advocate. (2019). Annual Report to Congress 2018. Washington, D.C.: \nTaxpayer Advocate Service\nNational Taxpayer Advocate. (2019). 2020 Purple Book, Compilation of Legislative \nRecommendations to Strengthen Taxpayer Rights and Improve Tax Administration. \nWashington, D.C.: Taxpayer Advocate Service\nNational Taxpayer Advocate. (2018). Annual Report to Congress 2017\n. Washington, D.C.: \nTaxpayer Advocate Service\nNational Taxpayer Advocate. (2018). 2019 Purple Book, Compilation of Legislative \nRecommendations to Strengthen Taxpayer Rights and Improve Tax Administration. \nWashington, D.C.: Taxpayer Advocate Service\nNational Taxpayer Advocate. (2017). Purple Book, Compilation of Legislative Recommendations \nto Strengthen Taxpayer Rights and Improve Tax Administration. Washington, D.C.: Taxpayer \nAdvocate Service\nNational Taxpayer Advocate. (2017). Annual Report to Congress 2016. Washington, D.C.: \nTaxpayer Advocate Service\nTaxpayer Advocacy Panel. (2019). Annual Report 2019. Washington, D.C.: Author\nTaxpayer Advocacy Panel. (2018). Annual Report 2018. Washington, D.C.: Author\nTaxpayer Advocacy Panel. (2017). Annual Report 2017\n. Washington, D.C.: Author\n", "226\nInternal Revenue Service \| Taxpayer First Act\nTaxpayer Advocacy Panel. (2016). Annual Report 2016. Washington, D.C.: Author\nTreasury Inspector General for Tax Administration. (2020). High Income Nonflers Owing Billions \nof Dollars Are Not Being Worked by the Internal Revenue Service. 2020-30-015. Washington \nD.C.: Author\nTreasury Inspector General for Tax Administration. (2020). Improvements Are Needed to \nAddress Continued Defciencies in Ensuring the Accuracy of the Centralized Authorization \nFile. 2020-40-067\n. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2019). Management and Performance \nChallenges Facing the Internal Revenue Service for Fiscal Year 2020. Washington D.C.: \nAuthor\nTreasury Inspector General for Tax Administration. (2019). Interim Results of the 2019 Filing \nSeason. 2019-44-030. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2019). Tax Cuts and Jobs Act: Assessment of \nImplementation Efforts. 2019-44-027\n. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2019). Telephone Performance Measures \nDo Not Provide an Accurate Assessment of Service to Taxpayers. 2019-40-041. Washington \nD.C.: Author\nTreasury Inspector General for Tax Administration. (2019). Fiscal Year 2019 Biannual \nIndependent Assessment of the Private Collection Agency Performance. 2019-30-018. \nWashington D.C.: Author\nTreasury Inspector General for Tax Administration. (2019). Electronic Authentication Security \nControls Have Improved, but Continued Progress Is Needed to Ensure the Protection of \nPublic-Facing Application. 2019-20-017\n. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2019). Management and Performance \nChallenges Facing the Internal Revenue Service for Fiscal Year 2020. Washington D.C.: \nAuthor\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "227\nInternal Revenue Service \| Taxpayer First Act\nTreasury Inspector General for Tax Administration. (2018). Interim Results of the 2018 Filing \nSeason. 2018-40-028. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2018). Results of the 2018 Filing Season. \n2018-40-013. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2018). Results of the 2017 Filing Season. \n2018-40-012. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2018). The Taxpayer Advocate Service \nCentralized Case Intake Program Needs Improvement to Provide Better Customer Service. \n2019-10-009. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2018). Electronic Authentication Process \nControls Have Been Improved, but Have Not Yet Been Fully Implemented. 2018-20-007\n. \nWashington D.C.: Author\nTreasury Inspector General for Tax Administration. (2016). Several Changes Sought by the \nInternal Revenue Service Restructuring and Reform Act of 1998 Remain a Challenge. 2016-\nIE-R005. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2016). Press Release: An Ongoing \nChallenge: Implementation of the Internal Revenue Service Restructuring and Reform Act of \n1998. IE-R005. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2016). Several Changes Sought by the \nInternal Revenue Service Restructuring and Reform Act of 1998 Remain a Challenge. \nTIGTA-2016-09. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2012). Management and Performance \nChallenges Facing the Internal Revenue Service for Fiscal Year 2013. Washington D.C.: \nAuthor\nBIBLIOGRAPHY\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "228\nInternal Revenue Service \| Taxpayer First Act\nTreasury Inspector General for Tax Administration. (2012). The Onboarding Process Has \nImproved, but Additional Steps Should Be T\naken to Ensure Employees Have the Tools, \nResources, and Knowledge to Be Successful and Productive. 2012-10-091. Washington \nD.C.: Author\nTreasury Inspector General for Tax Administration. (2010). The Internal Revenue Service \nRestructuring and Reform Act of 1998 Was Substantially Implemented but Challenges \nRemain. 2010-IE-R002. Washington D.C.: Author\nTreasury Inspector General for Tax Administration. (2010). Management and Performance \nChallenges Facing the Internal Revenue Service for Fiscal Year 2011\n. Washington D.C.: \nAuthor\nTreasury Inspector General for Tax Administration. (2003). Semiannual Report to Congress. \nWashington D.C.: Author. Accessed 04 August 2020\nTreasury Inspector General for Tax Administration. (1999). Semiannual Report to Congress. \nWashington D.C.: Author. Accessed 04 August 2020\nUnited States Government Accountability Office. (2020). DRAFT: Report to the Ranking Member, \nSubcommittee on Oversight, Committee on Ways and Means, House of Representatives: \nIRS Reorganization: Planning Addressed Key Reform Practices, but Goals and Measures \nfor the Plan Have Not Been Finalized. GAO-21-18. Washington, D.C.: Author \nUnited States Government Accountability Office. (2020). Report to Congressional Committees, \n2019 T\nax Filing: IRS Successfully Implemented Tax Law Changes but Needs to Improve \nService for Taxpayers with Limited-English Profciency. GAO-20-55. Washington, D.C.: Author \nUnited States Government Accountability Office. (2020). Report to the Chairman, Committee on \nFinance, U.S. Senate: Identity Theft: IRS Needs to Better Assess the Risks of Refund Fraud \non Business-Related Returns. GAO-20-174. Washington, D.C.: Author \nUnited States Government Accountability Office. (2019). Report to Congressional Committees: \nMultiple Strategies Are Needed to Reduce Noncompliance. GAO-19-558T. Washington, \nD.C.: Author \nBIBLIOGRAPHY\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "229\nInternal Revenue Service \| Taxpayer First Act\nUnited States Government Accountability Office. (2019). Report to Congressional Requestors: \nT\nax Administration: Taxpayer Input Could Strengthen IRS’s Online Services. GAO-20-71\n. \nWashington, D.C.: Author \nUnited States Government Accountability Office. (2019). Testimony Before the Committee on \nOversight and Reform, House of Representatives, High-Risk Series: Substantial Efforts \nNeeded to Achieve Greater Progress on High-Risk Areas. GAO-19-392T. Washington, D.C.: \nAuthor \nUnited States Government Accountability Office. (2019). Report to Congressional Committees, \nHigh-Risk Series: Substantial Efforts Needed to Achieve Greater Progress on High-Risk \nAreas. GAO-19-157SP\n. Washington, D.C.: Author \nUnited States Government Accountability Office. (2019). Report to Congressional Requesters, \nInternal Revenue Service: Strategic Human Capital Management is Needed to Address \nSerious Risks to IRS’s Mission. GAO-19-176. Washington, D.C.: Author \nUnited States Government Accountability Office. (2019). Tax Gap: Multiple Strategies Are \nNeeded to Reduce Noncompliance. GAO-19-558T. Washington, D.C.: Author\nUnited States Government Accountability Office. (2018). Report to Congressional Committees, \nT\nax Administration: Opportunities Exist to Improve Monitoring and T\nransparency of Appeal \nResolution Timeliness. GAO-18-659. Washington, D.C.:Author \nUnited States Government Accountability Office. (2018). Report to Congressional Requesters, \nIdentity Theft: IRS Needs to Strengthen Taxpayer Authentication Efforts. GAO-18-418. \nWashington, D.C.: Author \nUnited States Government Accountability Office. (2018). Report to Congressional Committees, \n2018 T\nax Filing: IRS Managed Processing Challenges and Enhanced Its Management of TX \nLaw Changes. GAO-18-471. Washington, D.C.:Author \nUnited States Government Accountability Office. (2018). Report to Congressional Requesters, \nGovernment Reorganization: Key Questions to Assess Agency Reform Efforts. GAO-18-427\n. \nWashington, D.C.: Author \nBIBLIOGRAPHY\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "230\nInternal Revenue Service \| Taxpayer First Act\nUnited States Government Accountability Office. (2017). Testimony Before the Subcommittee on \nOversight, Committee on Ways and Means, House of Representatives, 2017 Filing Season: \nNew Wage Verifcation Process Holds Promise but IRS Faced Implementation Challenges. \nGAO-17-525T. Washington, D.C.: Author \nUnited States Government Accountability Office. (2017). Report to Congressional Requesters, \n2016 Filing Season: IRS Improved Telephone Service but Needs to Better Assist Identity \nTheft Victims and Prevent Release of Fraudulent Refunds. GAO-17-186. Washington, D.C.: \nAuthor \nUnited States Government Accountability Office. (2017). Testimony Before the Committee on \nHomeland Security and Governmental Affairs, U.S. Senate, Government Efficiency and \nEffectiveness: Opportunities to Reduce Fragmentation, Overlap, and Duplication and \nAchieve Other Financial Benefts. GAO-17-562T. Washington, D.C.: Author \nUnited States Government Accountability Office. (2016). Testimony Before the Subcommittee on \nOversight, Committee on Ways and Means, House of Representatives, T\nax Filing: IRS Needs \na Comprehensive Customer Service Strategy and Needs to Better Combat Identity Theft \nRefund Fraud and Protect Taxpayer Data. GAO-16-578T. Washington, D.C.: Author \nUnited States Government Accountability Office. (2015). Report to Congressional Requesters, \n2015 T\nax Filing Season: Deteriorating T\naxpayer Service Underscores Need for a \nComprehensive Strategy and Process Efficiencies.GAO-16-151. Washington, D.C.: Author\nUnited States Government Accountability Office. (2013). Report to Chairman, Committee on \n \nFinance, U.S. Senate, IRS WEBSITE: Long-Term Strategy Needed to Improve Interactive \n \nServices. GAO-13-435. Washington, D.C.: Author\nUnited States Government Accountability Office. (2010). Report to Congressional Requesters, \nManaging for Results: Opportunities to Strengthen Agencies Customer Service Efforts. GAO-\n11-44. Washington, D.C.: Author \nUnited States Government Accountability Office. (2000). Report to the Chairman, Committee on \nSmall Business, U.S. Senate, Tax Administration: IRS Is Working to Improve Its Estimates of \nCompliance Burden. GAO/GGD-00-11. Washington, D.C.: Author \nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "231\nInternal Revenue Service \| Taxpayer First Act\nUnited States Government Accountability Office. (2000). Testimony Before the Committee on \nFinance, U.S. Senate, IRS RESTRUCTURING ACT: Implementation Under Way but Agency \nModernization Important to Success. GAO/T-GGD-00-53. Washington, D.C.: Author \nUnited States Government Accountability Office. (2000). Letter to Chairman, Committee \non Finance, U.S. Senate, IRS Restructuring Act Implementations. GAO/GGD-00-71R. \nWashington, D.C.: Author \nUnited States Government Accountability Office. (2000). Report to Congressional Requesters, \nTAX ADMINISTRATION: IRS’ Implementation of the Restructuring Act’s Personnel Flexibility \nProvisions. GAO/GGD-00-81. Washington, D.C.: Author \nUnited States Government Accountability Office. (2000). Report to Congressional Requesters, \nTAX ADMINISTRATION: IRS’ Implementation of the Restructuring Act’s Taxpayer Protection \nand Rights Provisions. GAO/GGD-00-85. Washington, D.C.: Author \nUnited States Government Accountability Office. (1998). Letter to Congressional Requesters, \nImpact of the IRS Restructuring and Reform Act on Year 2000 Efforts. GAO/GGD-98-158R. \nWashington, D.C.: Author \nUnited States Government Accountability Office. (1999). Report to the Chairman, Committee on \nWays and Means, House of Representatives, IRS Faces Challenges as it Restructures the \nOffice of the Taxpayer Advocate. GAO/GGD-99-124 Taxpayer Advocate Office. Washington, \nD.C.: Author\nUnited States Office of Management and Budget. (2019). T\nransition to Electronic Records. M-19-\n21\n. Washington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "232\nInternal Revenue Service \| Taxpayer First Act\n10.2 CUSTOMER SATISFACTION SURVEY RESULTS\nAccenture LLP. (2019). Small Business Taxpayer survey 2018. Washington, D.C.: Author\nAccenture LLP. (2017). Taxpayer Survey 2017: Report of U.S. Results. Washington, D.C.: Author\nCanada Revenue Agency. (2019). The Canada Revenue Agency: Brand and Service Culture \nJourney: Presentation to the Internal Revenue Service. Washington, D.C.: Author\nIRS Large Business & International. (2018). Study to Understand International Taxpayers’ Views \nof the Audit Experience: Report on FY2017 International Individual Compliance Survey \nResults. Washington, D.C.: Pacifc Consulting Group\nIRS Large Business & International. (2018). Study to Understand Taxpayers’ Views of the Audit \nExperience: Report on Fiscal Year 2018 Taxpayer Survey Results. Washington, D.C.: Pacifc \nConsulting Group \nIRS Large Business & International. (2018). Study to Understand International Taxpayers’ Views \nof the Audit Experience: Report on FY2018 International Individual Compliance Survey \nResults. Washington, D.C.: Pacifc Consulting Group\nIRS Large Business & International. (2017). Study to Understand Taxpayers’ Views of the Audit \nExperience: Report on Fiscal Year 2017 Taxpayer Survey Results. Washington, D.C.: Pacifc \nConsulting Group \nIRS Large Business & International. (2016). Compliance Assurance Process (CAP) Taxpayer \nExperience Survey Research: Covering Cases Closed in 2016. Washington, D.C.: Pacifc \nConsulting Group \nIRS Office of Appeals. (2019). Fiscal Year 2018 Appeals Customer Satisfaction Survey Results: \nNational Report. Washington, D.C.: ICF International\nIRS Office of Appeals. (2018). Fiscal Year 2017 Appeals Customer Satisfaction Survey Results: \nNational Report. Washington, D.C.: ICF International\nIRS Research, Applied Analytics & Statistics; Statistical Services Branch, Statistics of Income \n(SOI). (2020). Comprehensive Taxpayer Attitude Survey (CTAS) 2019: Appendix Report. \nWashington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "233\nInternal Revenue Service \| Taxpayer First Act\nIRS Research, Applied Analytics & Statistics; Statistical Services Branch, Statistics of Income \n(SOI). (2018). Comprehensive Taxpayer Attitude Survey 2017 Executive Overview: \nPresentation to the Research Policy and Planning Committee (RP&P) January 9, 2018. \nWashington, D.C.: Author\nIRS Small Business/Self-Employed. (2019). SB/SE ACS IVR Customer Satisfaction Report: \nSurvey Year 2018: April 2018 through March 2019. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2019). SB/SE ACSS Mail Customer Satisfaction Report: \nSurvey Year 2018: April 2018 through March 2019. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2019). SB/SE CSCO Mail Customer Satisfaction Report: \nSurvey Year 2018: April 2018 through March 2019. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2019). SB/SE Automated Underreporter Mail Customer \nSatisfaction Report: Survey Year 2018: April 2018 through March 2019. Washington, D.C.: \nAuthor\nIRS Small Business/Self-Employed. (2019). SB/SE Campus Exam Mail Customer Satisfaction \nReport: Survey Year 2018: April 2018 through March 2019. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2019). SB/SE Field Collection Mail Customer Satisfaction \nReport: Survey Year 2018: April 2018 through March 2019. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2018). SB/SE Field Collection Mail Customer Satisfaction \nReport: Survey Year 2017: April 2017 through March 2018. Washington, D.C.: Author \nIRS Small Business/Self-Employed. (2018). SB/SE Field Collection Mail Customer Satisfaction \nReport: Survey Year 2017: April 2017 through March 2018. Washington, D.C.: Author \nIRS Small Business/Self-Employed. (2018). SB/SE Estate & Gift Tax Customer Satisfaction \nReport: April 2017 through March 2018. Washington, D.C.: Author \nIRS Small Business/Self-Employed. (2018). SB/SE Employment Tax Customer Satisfaction \nReport: April 2017 through March 2018. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2018). SB/SE ISP Mail Customer Satisfaction Report: \nAnnual Period: April 2017 through March 2018. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2018). SB/SE Campus Exam Mail Customer Satisfaction \nReport: Survey Year 2017: April 2017 through March 2018. Washington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "234\nInternal Revenue Service \| Taxpayer First Act\nIRS Small Business/Self-Employed. (2018). SB/SE AUR Mail Customer Satisfaction Report: \nSurvey Year 2017: April 2017 through March 2018. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2018). SB/SE Field Exam Mail Customer Satisfaction \nReport: Survey Year 2017: April 2017 through March 2018. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2018). SB/SE CSCO Mail Customer Satisfaction Report: \nSurvey Year 2017: April 2017 through March 2018. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2018). SB/SE ACSS Mail Customer Satisfaction Report: \nSurvey Year 2017: April 2017 through March 2018. Washington, D.C.: Author\nIRS Small Business/Self-Employed. (2018). SB/SE ACS IVR Customer Satisfaction Report: \nSurvey Year 2017: April 2017 through March 2018. Washington, D.C.: Author\nIRS Tax Exempt & Government Entities Division. (2019). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: FY 2018 Tax-Exempt & Government Entities (TEGE) Toll-Free \nAnnual Report. Washington, D.C.: Author\nIRS Tax Exempt & Government Entities Division. (2018). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: Tax-Exempt Government Entity (TEGE) Toll-Free Report FY \n2017. Washington, D.C.: Author\nIRS Tax Exempt & Government Entities Division. (2018). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: Exempt Organizations Examinations. Washington, D.C.: \nAuthor\nIRS Tax Exempt & Government Entities Division. (2018). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: Tax Exempt Bonds Examinations. Washington, D.C.: Author\nIRS Tax Exempt & Government Entities Division. (2018). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: Employee Plans Examinations. Washington, D.C.: Author\nIRS Tax Exempt & Government Entities Division. (2018). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: Federal, State, and Local Government Examinations. \nWashington, D.C.: Author\nIRS Tax Exempt & Government Entities Division. (2018). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: Indian Tribal Government Examinations. Washington, D.C.: \nAuthor\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "235\nInternal Revenue Service \| Taxpayer First Act\nIRS Tax Exempt & Government Entities Division. (2017). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: Exempt Organizations Determination Letter Request. \nWashington, D.C.: Author\nIRS Tax Exempt & Government Entities Division. (2017). Internal Revenue Service: TE/GE \nCustomer Satisfaction Survey: Employee Plans Determination Letter Request. Washington, \nD.C.: Author\nIRS Taxpayer Advocate Service. (2019). TAS Customer Satisfaction Program – FY2018. \nWashington, D.C.: Author\nIRS Wage & Investment Division. (2019). Internal Revenue Service: Customer Satisfaction \nSurvey: FY 2018 W&I Refundable Credits Examination Operations (RCEO) Closed Annual \nReport. Washington, D.C.: Author\nIRS Wage & Investment Division. (2019). Internal Revenue Service: Customer Satisfaction \nSurvey: FY 2018 W&I Refundable Credits Examination Operations (RCEO) Toll-Free IVR \nAnnual Report. Washington, D.C.: Author\nIRS Wage & Investment Division. (2019). Taxpayer Experience Survey (TES) 2018 National \nReport. Washington, D.C.: ICF International \nIRS Wage & Investment Division. (2019). Internal Revenue Service: Customer Satisfaction \nSurvey: FY 2018 Practitioner Priority Service (PPS) Toll-Free Annual Report. Washington, \nD.C.: Author \nIRS Wage & Investment Division. (2019). Internal Revenue Service: Customer Satisfaction \nSurvey: FY 2018 Accounts Management (AM) Toll-Free Annual Report. Washington, D.C.: \nAuthor\nIRS Wage & Investment Division. (2019). Internal Revenue Service: Customer Satisfaction \nSurvey: FY 2018 Adjustments Closed Case Annual Report. Washington, D.C.: Author\nIRS Wage & Investment Division. (2019). Internal Revenue Service: Customer Satisfaction \nSurvey: FY 2018 W&I e-help Desk Toll-Free Annual Report. Washington, D.C.: Author\nIRS Wage & Investment Division. (2019). Internal Revenue Service: Customer Satisfaction \nSurvey: Wage & Investment: Stakeholder Partnerships, Education and Communication \n(SPEC) Partner Satisfaction Survey FY 2018 Full Report. Washington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "236\nInternal Revenue Service \| Taxpayer First Act\nIRS Wage & Investment Division. (2019). Internal Revenue Service: Customer Satisfaction \nSurvey: Wage & Investment: Media and Publications External Customer Satisfaction Survey \n(ECSS): FY 2018 Annual Report. Washington, D.C.: Author\nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: Field Assistance National Annual Report FY2017. Washington, D.C.: Author\nIRS Wage & Investment Division. (2018). Taxpayer Experience Survey (TES) 2017 Spanish \nLimited English Profcient (LEP) Report. Washington, D.C.: ICF International \nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: Adjustments Closed Case Report FY2017. Washington, D.C.: Author\nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: Accounts Management (AM) Toll-Free Report FY2017. Washington, D.C.: Author\nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: W&I e-help Desk Toll-Free Report FY2017. Washington, D.C.: Author \nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: FY2018 Field Assistance National Annual Report. Washington, D.C.: Author \nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: Injured Spouse Closed Case Report FY 2017. Washington, D.C.: Author \nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: Wage & Investment: Media and Publications External Customer Satisfaction Survey \n(ECSS): FY 2017 Annual Report. Washington, D.C.: Author \nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: Practitioner Priority Service (PPS) Toll-Free Report: FY 2017 Annual Report. \nWashington, D.C.: Author \nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: Refundable Credits Examination Operations (RCEO) Close Case Report: FY 2017. \nWashington, D.C.: Author\nIRS Wage & Investment Division. (2018). Internal Revenue Service: Customer Satisfaction \nSurvey: W&I Refundable Credits Examination Operations (RCEO) Toll-Free IVR Report FY \n2017. Washington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "237\nInternal Revenue Service \| Taxpayer First Act\nIRS Wage & Investment Division. (2017). Internal Revenue Service: Customer Satisfaction \nSurvey: Wage & Investment: Stakeholder Partnerships Education and Communication \n(SPEC) Partner Satisfaction Survey: FY 2017 Annual Report. Washington, D.C.: Author\nFederal Consulting Group. (2018). American Customer Satisfaction Index: Internal Revenue \nService: Department of the Treasury: Individual E-Filers: 2018 Customer Satisfaction Survey. \nWashington, D.C.: Author\nFederal Consulting Group. (2018). American Customer Satisfaction Index: Internal Revenue \nService: Department of the Treasury: Large Business & International Division: 2018 \nCustomer Satisfaction Survey. Washington, D.C.: Author\nFederal Consulting Group. (2018). American Customer Satisfaction Index: Internal Revenue \nService: Department of the Treasury: Individual Paper Filers: 2018 Customer Satisfaction \nSurvey. Washington, D.C.: Author\nFederal Consulting Group. (2018). American Customer Satisfaction Index: Internal Revenue \nService: Department of the Treasury: Small Business/Self Employed:2018 Customer \nSatisfaction Survey. Washington, D.C.: Author\n10.3 PUBLICATIONS, STUDIES, \n BRIEFINGS AND STATUTES\nAccenture LLP. (2019) Breaking Through Functional Silos: To Gain Speed and Agility: Achieve \nCompetitive Agility. Washington, D.C.: Author \nAccenture LLP & Partnership for Public Service. (2019) Government for the People: Profles on \nthe customer experience. Washington, D.C.: Accenture LLP\nAccenture LLP & Partnership for Public Service. (2016) Government for the People: The road to \ncustomer-centered services. Washington, D.C.: Accenture LLP\nAmazon. (2020). Amazon.com Inc. Board of Directors Guidelines on Signifcant Corporate \nGovernance Issues. Accessed 14 August 2020. \nAdams, Faith. (2018). Applying the Forrester Wave™: Customer Feedback Management \nPlatforms, Q4 2018 How to Identify the Right CFM Vendor For Your Business. Cambridge, \nMA: Forrester Research, Inc.\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "238\nInternal Revenue Service \| Taxpayer First Act\nAdams, Faith. (2018). Now Tech: Voice of The Customer (VoC) Vendors, Q4 2018 Forrester’s \nOverview of 28 VoC Providers. Cambridge, MA: Forrester Research, Inc.\nAdams, Faith. (2018). The Forrester Wave™: Customer Feedback Management Platforms, \nQ4 2018 The Nine Providers That Matter Most and How They Stack Up. Cambridge, MA: \nForrester Research, Inc.\nAlexander, William & Anterasian, Cathy & Welch, Greg. (2015). Do We Need a CXO? \nSpencerStuart. Accessed 14 August 2020. \nAlexander, Moira. “What is an EPMO? The organizational key to project success.” CIO. 6 July \n2018, https://www.cio.com/article/3277972/epmo-enterprise-project-management-office-\nexplained.html. 19 Aug. 2019\nAlm, James. (2012). Measuring, Explaining, and Controlling Tax Evasion: Lessons From Theory, \nExperiments, and Field Studies. Switzerland: International Tax and Public Finance.\nAnderson, Carl & Li, Michael. (2017). Five Building Blocks of Data-Driven Culture. Tech Crunch. \nAccessed 14 August 2020. \nAustralian Taxation Office. (2018) Commissioner of Taxation Annual Report 2017-18. Canberra \nACT, Australia \nAustralian Taxation Office. “ATO Fraud and Corruption Control Plan 2019.” Australian \nGovernment: Australian Taxation Office. 26 Feb. 2020, https://www.ato.gov.au/General/The-\nfght-against-tax-crime/In-detail/ATO-Fraud-and-Corruption-Control-Plan-2019-20/. 19 Aug. \n2020\nBank of America. (2019). What Would You Like the Power to Do?: 2018 Annual Report. \nCharlotte, NC: Author \nBeeson, John. (2014). Five Questions Every Leaders Should Ask About Organizational Design. \nHarvard Business Review. Accessed 14 August 2020.\nBernstein, Ethan & Bunch, John & Canner, Niko & Lee, Michael. (2016). Beyond the Holacracy \nHype. Boston, MA: Harvard Business Review.\nBlenko, Marcia M, & Mankins, Michael C. (2012). Measuring Decision Effectiveness: Good, Fast \nDecision Making and Execution Produce Good Financial Results. Bain & Company. \nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "239\nInternal Revenue Service \| Taxpayer First Act\nBlomstrom, Duena. “We Need To Talk About Organizational Design.” Forbes. 5 Nov. 2018, \nhttps://www.forbes.com/sites/duenablomstrom1/2018/11/05/we-need-to-talk-about-\norganisational-design/#54f02cd71604. Accessed 14 Aug. 2020\nBonner, Paul. (2020). IRS commissioner and other officials address AICPA National Tax \nConference in Washington. TheTaxAdviser.com: The Tax Adviser\nBoyd, Aaron. (2020). IRS Offering Up to $7M to Develop ‘Data Mashing’ Tools In Support of \nFrictionless Acquisition. Nextgov.com: Nextgov\nBrimstin, Jay., Hester, Annie., “Measuring What Matters.” Association for Talent Development. \nMay 2016, https://www.td.org/magazines/the-public-manager/measuring-what-matters. \nAccessed 6 January 2020\nCanada Revenue Agency. (2019). Reputational Risk Management: Presentation to IRS \nCommissioner, Executive Risk Committee and Chief, Communication and Liaison October \n31, 2019. Ottawa, Canada: Author\nCapital One. “Using Machine Learning to Re-Think the Customer Experience Paradigm.” Capital \nOne. 13 Nov. 2018, https://www.capitalone.com/tech/machine-learning/using-machine-\nlearning-to-re-think-the-customer-experience-paradigm/. Accessed 18 Nov. 2019\nCardona-Smits, Karine. (2019). Service Design Improves CX By Bridging Silos Companies \nwith Fragmented CX Efforts Can Do Better by Learning the Service Design Approach. \nCambridge, MA: Forrester Research, Inc.\nCasciaro, Tiziana & Edmondson, Amy & Jang, Sujin. (2019). Cross-Silo Leadership. Cambridge, \nMA: Harvard Business Publishing. Accessed 14 August 2020.\nCentric Strategy. “Too Many Chiefs? How CDOS, CIOS, CTOS, and CMOS Must Work \nTogether.” 6 Sept. 2017, https://centricdigital.com/blog/digital-strategy/cdos-cio-cto-cmo/. \nAccessed 14 Aug. 2020\nComcast. (2018). Employee Spotlight: Charlie Herrin: From Designing X1 to Chief Customer \nExperience Officer. Author. Accessed 14 August 2020.\nCongressional Budget Office. (2020). Trends in the Internal Revenue Service’s Funding and \nEnforcement. Washington D.C.: Author\nConsolidated Appropriations Act, Pub. L. No 116-93, H.R.1158 (2020)\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "240\nInternal Revenue Service \| Taxpayer First Act\nCzech Republic: Financni Sprava. (2020). Organization Structure. Czech Republic: Author\nCzech Republic: Ministry of Finance. (2020). Public Budgets. Czech Republic: Author\nDaude, Christian, & Gutierrez, Hamlet, & Melguizo, Angel. (2012). What Drives Tax Morale? \nParis, OECD.\nDavis, Stanley M., & Lawrence Paul R. (1978). Problems with Matrix Organizations. Boston, MA: \nHarvard Business Review \nDeloitte Touche Tohmatsu Limited. (2016). The evolving role of the chief data officer in fnancial \nservices: From marshal and steward to business strategist. London, United Kingdom. Author \nDen Haan, Johan. “10 Reasons Why You Should Organize a FedEx Day.” The Enterprise \nArchitect. 23 July 2013, http://www.theenterprisearchitect.eu/blog/2013/07/23/10-reasons-\norganize-fedex-day/. Accessed 14 Aug. 2020 \nDe Smet, Aaron & Jost, Gregor & Wess, Leigh. “Want a better decision? Plan a better meeting.” \nMcKinsey & Company. 8 May 2019, https://www.mckinsey.com/business-functions/\norganization/our-insights/want-a-better-decision-plan-a-better-meeting. Accessed 4 Aug. \n2020 \nDigital Surgeons. “Three Businesses Beneftting From Cross Functional Teams.” 22 Mar. 2017, \nhttps://www.digitalsurgeons.com/thoughts/design-thinking/three-businesses-beneftting-from-\ncross-functional-teams/. Access 14 Aug. 2020\nDonovan, Shaun. (2016). Memorandum to the Heads of Executive Departments and Agencies: \nOMB Circular No. A-123, Managements Responsibility for Enterprise Risk Management and \nInternal Control. Washington D.C.: Executive Office of the President: Office of Management \nand Budget\nDownes, Andrew. “4 Learning Evaluation Models You Can Use.” eLearning Industry. 20 January \n2016, https://elearningindustry.com/4-learning-evaluation-models-can-use. Accessed 6 Jan. \n2020\nEllis, Ryann K. “Popular Learning Evaluation Models: An Infographic.” Association for Talent \nDevelopment. 29 April 2015, https://www.td.org/insights/popular-learning-evaluation-models-\nan-infographic. Accessed 6 Jan. 2020\nEngagement Bureau. (2013). MasterCard Inaugurates Advanced Analytics Center of Excellence \nin India. http://bit.ly/18KqLLT. Accessed 22 Aug. 2020\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "241\nInternal Revenue Service \| Taxpayer First Act\nElectronic Tax Administration Advisor Committee. “Electronic Tax AdmiOJstration Advisor \n(ETAAC).” https://www.irs.gov/newsroom/electroinic-tax-administration-advisory-committee-\netaac. Accessed 4 August 2020.\nExasol GmbH. “2019 Data Decisions Survey: How Businesses Use Data to Make Critical \nDecisions”, https://www.exasol.com/en/resource/2019-data-decisions-survey-how-\nbusinesses-use-data-to-make-critical-decisions/. Accessed 4 Aug. 2020\nExecutive Office of the President and President’s Management Council. (2018). President’s \nManagement Agenda. Washington, D.C.: Author\nFlorida Tech. (2020). Chief Information Officer Career and Salary Profle. Melbourne, FL.: Author.\nForbes Insights. (2019). Rethinking the Role of Chief Data Officer. Insights Contributor.\nForesee. (2019). US Department of Treasury: Tax Season Analysis. Washington, D.C.: IRS Office \nof Online Services\nForesee. (2019). Customer Satisfaction Report: IRS Automated Clearing House. Washington, \nD.C.: IRS Office of Online Services\nForrester Research, Inc. (2019). Consumer Technographics Overview. Cambridge, MA: Author\nForrester Research, Inc. (2019). Consumer Technographics Overview. Cambridge, MA: Author\nForrester Research, Inc. (2019). Light on the Horizon: The State of Customer Experience Quality. \nCambridge, MA: Author\nForrester Research, Inc. (2019). Consumer Technographics North American Financial Services \nOnline Benchmark Recontact Survey. Cambridge, MA: Author\nForrester Research, Inc. (2018). CX Index Overview. Cambridge, MA: Author\nFournier, Alexis. “Innovation Metrics & KPIs: Measuring Innovation to Create Growth.” 14 Nov. \n2019 https://www.braineet.com/blog/innovation-metrics-kpis/. Accessed 4 Aug. 2020\nFraud Reduction and Data Analytics Act of 2015, 114 U.S.C. § 186 (2015)\nFrazee, Bonnie. Corporate Universities: A Powerful Model for Learning, Chief Learning Officer, \n1 November 2002, https://www.chiefearningofficer.com/2002/11/01/corporate-universities-a-\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "242\nInternal Revenue Service \| Taxpayer First Act\npowerful-model-for-learning/, Accessed 21 Jan. 2020\nGartner, Inc. (2020). 9 Questions That Should Be in Every Employee Engagement Survey.\nStamford, CT: Author\nGeneral Services Administration. (2019). Customer Experience: Maximize the Impact of Your \nInitiatives. Washington, D.C.: Author\nGennis, Angelina, & Brink-Quintanilha, Joana van den, & Keitt, TJ. (2019). The Defnitive Guide \nto Forrester’s Journey Mapping Research. Cambridge, MA:Forrester Research, Inc.\nGrossman, David. (2014). Secret Google Lab ‘Rewards Staff for Failure’. BBC Newsnight. \nGovernment Accountability Office. ”About GAO”. https://www.gao.gov/about/. Accessed 10 Aug. \n2020.\nGovernment of Canada. (2018). 2019 – 20 Departmental Plan. https://www.canada.ca/en/\nrevenue-Agency. Accessed 14 Aug. 2020. \nGulati, Ranjay & Rivkin, Jan & Raffaelli, Ryan. (2016). Does “What We Do” Make Us “Who We \nAre”? Organizational Design and Identity Change at the Federal Bureau of Investigation. \nHarvard Business School.\nHalf, Robert. (2019). Chief Experience Officer Job and Salary. Accessed 14 Aug. 2020.\nHanover Research. (2010). Best Practices and Strategies in Organizational Structure and \nDesign. Washington, D.C.: Author\nHarris, Atmar, & Becdach, Camilo & Kleinman, Sarah, & Rieckhoff. “Bridging the gap between \na company’s strategy and operating model.” McKinsey & Company. May 2019, https://www.\nmckinsey.com/business-functions/organization/our-insights/bridging-the-gap-between-a-\ncompanys-strategy-and-operating-model.Accessed 13 Nov. 2019 \nHedges, Kristi. “How To Drive Innovation In Five Steps.” Forbes. 10 April 2014https://www.forbes.\ncom/sites/work-in-progress/2014/04/10/how-to-drive-innovation-in-fve-steps/#3107a7533d4b. \nAccessed 14 Aug. 2020\nHiatt, Jeffrey & Creasey, Timothy. (2012). Change Management: The People Side of Change. \nFort Collins, CO: Prosci Learning Center Publications\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "243\nInternal Revenue Service \| Taxpayer First Act\nInland Revenue of Authority of Singapore. “Taxpayer Feedback Panel.” http://www.iras.gov.sg/.\nAccessed 28 Feb. 2020\nInspector General Act of 1978, Pub. L. No. 95–452, 92 Stat. 1101 (1978)\nIntegris Software, Inc. (2020). Data Governance Overview: Best Practices and Tools to Support \nan Enterprise DG Program. Seattle, WA: Integris Software. Accessed 14 August 2020.\nInternal Revenue Service Restructuring and Reform Act of 1998, Pub. L. No. 105-206, 1998 Stat. \n685 (1998)\nInternal Revenue Service. (2018). Candidate Development Program Summer 2018: Strategic \nBusiness Case – Restructuring the IRS. Washington, DC.: Author\nInternal Revenue Service. Collection Individual Masterfle Delinquent Returns All Nonflers. \nCompliance Data Warehouse (2020): IRS Internal System. 5 Aug. 2020.\nInternal Revenue Service. Enforcement Revenue Information System. Compliance Data \nWarehouse (2020): IRS Internal System. 5 Aug. 2020.\nInternal Revenue Service. Individual Masterfle Transaction History. ComplianceData Warehouse \n(2020): IRS Internal System. 5 Aug. 2020.\nInternal Revenue Service. (2020). Report to the Committees on Appropriations: P.L. 116-93: IRS \nCybersecurity Audit Recommendations. Washington, D.C.: Author\nInternal Revenue Service. (2020). IRS Integrated Modernization Business Plan: FY2019 Key \nInsights Report. Washington, D.C.: Author\nInternal Revenue Service. (2020). FT 2022 Treasury Budget Responses. Washington, D.C.: \nAuthor\nInternal Revenue Service. (2020). Taxpayer First Act Office: TIGTA / IRS Criminal Investigation \nInsights. Washington, D.C.: Author\nInternal Revenue Service. (2020). Publication 6961: Calendar Year Projections of Information \nand Withholding Documents for the United States and IRS Campuses. Washington, D.C.: \nAuthor\nInternal Revenue Service. (2020). Publication 6962: Fiscal Year Return Projections for the \nUnited States: 2020 – 2027: Spring 2020. Washington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "244\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service. (2019). Customer Experience Cross-Agency Priority Goal 4 (CX \nCAPG): Overview for Taxpayer First Act Office. Washington, D.C.: Author\nInternal Revenue Service. (2019). IRS Integrated Modernization Business Plan. Washington, \nD.C.: Author\nInternal Revenue Service. (2019). IRS Integrated Modernization Business Plan: Measuring \nProgress and Success. Washington, D.C.: Author\nInternal Revenue Service. (2019). Taxpayer First Act Office: Overview of the Management \nChallenges Reports created by TIGTA: December 2019. Washington, D.C.: Author\nInternal Revenue Service. (2019). Taxpayer First Act Office: Industry Best Practices Research: \nDecember 2019. Washington, D.C.: Author\nInternal Revenue Service. (2019). CAP Goal 1 – IT Modernization Measures. Washington, D.C.: \nAuthor\nInternal Revenue Service. (2019). CAP Goal 3 – Workforce of the Future Measures. Washington, \nD.C.: Author\nInternal Revenue Service. (2019). CAP Goal 4 – Improving Customer Experience – FY19 Q4 CX \nFeedback Internal Revenue Service. Washington, D.C.: Author\nInternal Revenue Service. (2019). IRS Business Operating Divisions Co-Location of Services \nReport. Washington, D.C.: Author\nInternal Revenue Service. (2019). 21st Century IDEAct Working Group Session. Washington, \nD.C.: Author\nInternal Revenue Service. (2019). 2019 Internal Revenue Service: Data Book. Washington, D.C.: \nAuthor\nInternal Revenue Service. (2019). Publication 6187: Calendar Year Projections of Individual \nReturns by Major Processing Categories, Selected Years and Areas: Fall 2019. Washington, \nD.C.: Author\nInternal Revenue Service. (2019). Publication 6186: Calendar Year Return Projections for the \nUnited States and IRS Campuses: 2019. Washington, D.C.: Author\nInternal Revenue Service. (2019). Publication 6149: Calendar Year Return Projections for the \nUnited States and IRS Campuses: 2019. Washington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "245\nInternal Revenue Service \| Taxpayer First Act\nInternal Revenue Service. (2018). SB/SE Collection & RAAS: CP14 Notice Redesign: Test Pilot \nReport. Washington, D.C.: Author\nInternal Revenue Service. (2016). IRS Future State: The Path Traveled and the Road Ahead. \nWashington, D.C.: Author\nInternal Revenue Service. (2016). Future State Concept Diagram. Washington, D.C.: Author\nInternal Revenue Service. (2016). W&I Filing Season Readiness/Future State Preparations. \nWashington, D.C.: Author\nInternal Revenue Service. (2016). Tax Gap Estimates for Tax Years 2008-2010. Washington, \nD.C.: Author\nInternal Revenue Service. (2013). Revised IRM 1.1.4 Organizational Planning. Internal Revenue \nManual. August 6, 2013. Washington, D.C.: Author\nInternal Revenue Service. (2000). IRS Organizational Blueprint. Washington, D.C.: Author\nInternal Revenue Service. (1999). 1999 Modernizing America’s Tax Agency. Washington, D.C.: \nAuthor\nInternal Review Service. (2017). Internal Review Service Strategic Plan FY2018 – 2022. \nWashington, D.C.: Author. \nIrish Tax and Customs. (2020). Corporate, Revenue, Governance. Dublin, Ireland.: Author \nIRS Chief Financial Officer – Strategic Planning Office. (2019). IRS Corporate Performance \nMeasures & Reporting. Washington, D.C.: Author\nIRS Information Technology. (2019). Technology Business Management (TBM) IT Tower \nBenchmarks. Washington, D.C.: Author\nIRS Office of Online Services. (2019). Payment Plan: Foresee and GA Analysis. Washington, \nD.C.: Author\nIRS Oversight Board. “About “Us – IRS Oversight Board”. https://www.irs.gov/tax-professionals/\ninternal-revenue-service-advisory-council-irsac. Accessed 4 Aug. 2020.\nIRS Research, Applied Analytics and Statistics. (2019). Foundations for Evidence-Based Policy \nMaking Act of 2018. Washington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "246\nInternal Revenue Service \| Taxpayer First Act\nIRS Office of Research: Research, Analytics and Statistics. (2014). Inattention & Tax Benefts: \nThird-Party Reporting & IRS Outreach to Low-Income Nonflers. Washington, D.C.: Author\nIRS Taxpayer First Act Office. (2020). Job Profles for CIO, CDO and CXO. Washington, D.C.: \nAuthor\nIRS Taxpayer First Act Office. (2020). Document Research Methodology Overview. Washington, \nD.C.: Author\nIRS Taxpayer First Act Office. (2020). Review of: The Reorganization Act of 1998; 1997 \nCommission Report on Restructuring; Prior Organization Structures. Washington, D.C.: \nAuthor\nIRS Taxpayer First Act Office. (2019). Global Revenue Agencies Peer Research. Washington \nD.C.: Author\nIRS Wage & Investment Division. (2019). Wage & Investment Division: Business Performance \nReview. Washington, D.C.: Author\nIRS Wage & Investment Division: Research & Analysis Group. (2019). Customer Experience \nService Delivery (CX/SD) Plan. Washington, D.C.: Author\nIRS Wage & Investment Division: Research & Analysis Group. (2010). Understanding the \nInternational Taxpayer Experience: Service Awareness, Use, Preferences, and Filing \nBehaviors. Washington, D.C.: Author\nIRS Wage & Investment Division: Strategies & Solutions. (2020). Service Channel Migration \nConjoint Study. Washington, D.C.: Author\nIRS Wage & Investment Division. (2020). Wage & Investment Operations Plan FY 2020. \nWashington, D.C.: Author\nIRS Wage & Investment Division. (2019). W&I CX Measure List. Washington, D.C.:Author\nIRS Wage & Investment Division. (2018). Facilitating Taxpayer Access to Convenient and \n \n Efficient IRS Services: W&I Web-First Conjoint Study. Washington, D.C.: Pacifc Consulting \n Group\nIrish Tax and Customs. (2019) “Annual Report 2018”. www.revenue.ie. Accessed 18 Aug. 2020\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "247\nInternal Revenue Service \| Taxpayer First Act\nJacobs, Ian, & Leggett, Kate. (2018). Better Governance Leads to Better Customer Service — \nYes, Really! Processes: The Contact Centers for Customer Service Playbook. Cambridge, \nMA: Forrester Research, Inc. \nJacobs, Ian, & Leggett, Kate. (2018). Implement Effective Customer Service Metrics \nBenchmarks: The Contact Centers for Customer Service Playbook. Cambridge, MA: \nForrester Research, Inc. \nJapan National Tax Agency. (2019) National Tax Agency Annual Report.” https://www.nta.go.jp/\nenglish/Report_pdf/2019e.pdf. Tokyo, Japan.: Author\nJoshi, Naveen. (2018). Choosing The Right Center of Excellence Style For Integrating Artifcial \nIntelligence. Forbes. Accessed 14 August 2020.\nJPMorgan Chase & Co. (2019). Corporate Governance Principles of JPMorgan Chase & CO. \n(the “Firm”). New York, NY: JPMorgan Chase & Co. Accessed 4 Aug 2020.\nLeggett, Kate, & Jacobs, Ian. (2019). Gauge Your Customer Service Maturity Assessment: The \nContact Centers for Customer Service Playbook. Cambridge, MA: Forrester Research, Inc. \nLeggett, Kate, & Jacobs, Ian. (2019). The Future of Work: You Must Change How You Hire \nCustomer Service Agents Workforce Transformation Must Come Before Automation. \nCambridge, MA: Forrester Research, Inc. \nLeih, Sunyoung & Linden, Greg & Teece, David. (2015). Business Model Innovation and \nOrganizational Design: A Dynamic Capabilities Perspectiv. Berkeley, CA: UC Berkeley. \nLumen Candela. Common Organizational Structures: Functional Structures. Accessed 14 \nAugust 2020. \nMarr, Bernard. “Want To Be A Chief Data Officer? Here’s What You Need To Know.” Forbes. 20 \nMay 2016 https://www.forbes.com/sites/bernardmarr/2016/05/20/want-to-be-a-chief-data-\nofficer-heres-what-you-need-to-know/#486d44a3278d. Accessed 14 Aug. 2020\nMocker, Martin, & Ross, Jeanne W., & Beath, Cynthia M. (2019). How Companies UseDigital \nTechnologies to Enhance Customer Offerings – Summary of Survey Findings. Cambridge, \nMA: MIT Sloan Center for Information Systems Research\nMordechia, Gal. (2015). What is the Difference Between Centers of Excellence and Innovation \nLabs? Gal’s Insights. Accessed 14 Aug 2020. \nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "248\nInternal Revenue Service \| Taxpayer First Act\nMorgan, Blake. “The 20 Best Customer Experience Metric For You Business.” Forbes. 29 \nJuly 2019 https://www.forbes.com/sites/blakemorgan/2019/07/29/the-20-best-customer-\nexperience-metrics-for-your-business/#14b77d3158cc. Accessed 4 Aug. 2020\nMorgan, Jacob. “The 5 Types Of Organizational Structures: Part 3, Flat Organizations.” \nForbes. 13 July 2015 https://www.forbes.com/sites/jacobmorgan/2015/07/13/the-5-types-of-\norganizational-structures-part-3-fat-organizations/#216c1c0c6caa. Accessed 13 Nov. 2019\nNational Commission on Restructuring the Internal Revenue Service. (1997). Report of the \nNational Commission on Restructuring the Internal Revenue Service: A Vision for a New \nIRS. Washington, D.C.: Author\nNational Treasury Employees Union. (2020). National Treasury Employees Union Taxpayer First \nAct Recommendations. Washington, D.C.: Author\nNational Treasury Employees Union. (2020). IRS Update: IRS Releases Information on Taxpayer \nFirst Act. Washington, D.C.: Author\nNeilson, Gary L., & Estupinan, Jaime, & Sethi Bhushan. “10 Guiding Principles of Organization \nDesign.” Forbes. 1 April 2015, https://www.forbes.com/sites/strategyand/2015/04/01/10-\nguiding-principles-of-organization-design/#5c5e2c3b5888. Accessed 11 Nov. 2019 \nNew York Times. “How to Run an Effective Meeting.” New York Times.https://www.nytimes.com/\nguides/business/how-to-run-an-effective-meeting Accessed 4 Aug. 2020\nNovet, Jordan. “Why LinkedIn’s data science reorg actually makes a lot of sense.” Venture Beat. \n3 Nov. 2014, https://venturebeat.com/2014/11/03/linkedin-data-scientists-analysis/. 14 Aug. \n2020\nOECD. (2019). Forum on Tax Administration: Implementing Online Cash Registers: Benefts, \nConsiderations and Guidance. Paris, France: Author\nOECD. (2019). Forum on Tax Administration: Successful Tax Debt Management: Measuring \nMaturity and Supporting Change. Paris, France: Author\nOECD. (2019). Forum on Tax Administration: Unlocking the Digital Economy: A Guide to \nImplementing Application Programming Interfaces in Government. Paris, France: Author\nOECD. (2016). Rethinking Tax Services: The Changing Role of Tax Service Providers in SME \nTax Compliance. Paris, France: Author\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "249\nInternal Revenue Service \| Taxpayer First Act\nOffice of Management and Budget. “About Office of Management and Budget”.https://www. \n \nwhitehouse.gov/omb/. Accessed 10 Aug. 2020.\nOffice of Management and Budget. (2019). OMB Circular No. A-11: Section 280 – Managing \n \n \nCustomer Experience and Improving Service Delivery. Washington, D.C.: Author \nOffice of Management and Budget. (2019). OMB M-19-21: Memorandum For Heads Of \n \nExecutive Departments and Agencies, Transition to Electronic Records. Washington, \n \nD.C.: Author\nOffice of Personnel Management. ”Federal Employee Viewpoint Survey”. www.opm.gov/fevs/\nabout. Accessed 25 September 2020.\nOffice of Personnel Management. (2018). Federal Employee Viewpoint Survey: Annual \n \nEmployee Survey Report: Department of the Treasury. Washington, D.C.: Author\nOffice of Personnel Management. (2016). Building an Engaging Workplace: Understanding and \n \nUsing Engagement Drivers. Washington, D.C.: Author\nOffice of Personnel Management. (2016). Governmentwide Inclusive Diversity Strategic Plan. \n \nPresident Obama, Executive Order 13583\nOffice of Personnel Management. (2011). Training Evaluation Field Guide. Washington, D.C.: \n \nAuthor\nOverby, Stephanie. “What’s The Best Reporting Structure for the CISO?” SecurityRoundtable. \n \norg. 29 April 2018, https://www.securityroundtable.org/whats-the-best-reporting-structure- \n \nfor-the-ciso/. Accessed 4 Aug. 2020 Pasto, Riccardo. (2017). Elevate Your Customer \n \nExperience with End-To-End Customer \nService Superior Customer Service Evokes Positive Emotions to Create Business Value. \n \nCambridge, MA: Forrester Research, Inc.\nParrish, Rick, & Tramm, Laura Garvin. (2019). The US Federal Customer Experience Index, \n \n2019: How US Federal Government Agencies Drive Mission Performance With the \n \nQuality of Their Experience. Cambridge, MA: Forrester Research, Inc.\nParrish, Rick. (2019). Forrester’s Top Customer Experience Research Findings Of 2018. \n \nCambridge, MA: Forrester Research, Inc.\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "250\nInternal Revenue Service \| Taxpayer First Act\nParrish, Rick. (2018). The US Federal Government Still Ranks Near the Bottom of Forrester’s \nCustomer Experience Index. Cambridge, MA: Forrester Research, Inc. \nParrish, Rick, & Tramm, Laura Garvin. (2018). Why and How to Improve Government CX. \nCambridge, MA: Forrester Research, Inc. \nPhillips Erb, Kelly. “Hold, Please: Customer Service Still a Challenge for IRS. Daily Tax Report.” \n31 October 2019, https://news.bloombergtax.com/daily-tax-report/hold-please-customer-\nservice-still-a-challenge-for-irs. Accessed 13 Nov. 2019\nPrice, Kelly. (2018). The Customer Journey Atlas in Six Steps: How to Organize and Prioritize \nYour Journey Mapping Efforts for Success. Cambridge, MA: Forrester Research, Inc. \nRio, Ave. The Future of the Corporate University. Chief Learning Officer. 3 May 2018, https://\nww.chiefearningofficer.com/2018/05/03/future-corporate-university/. Accessed 21 January \n2020\nRivier University. “How to Become a CIO.” Rivier Academics.https://www.rivier.edu/academics/\nonline/resources/career-outcomes/chief-information-officer. Accessed 15 Aug.2020\nRogelberg, Steven. (2019). Why Your Meetings Stink – and What to Do About It. Boston, MA: \nHarvard Business Review.\nRoss, Jeanne W., & Mocker, Martin, & Beath, Cynthia M. (2019). Five Building Block of Digital \nTransformation. Cambridge, MA: MIT Sloan Center for Information Systems Research\nRoss, Jeanne W., & Beath, Cynthia M., & Jha, Lipsa, & the Technology Advantage Practice of \nThe Boston Consulting Group (2017). Designing Digital Organizations – Summary of Survey \nFindings. Cambridge, MA: MIT Sloan Center for Information Systems Research\nRossotti, C. O. (2005). Many Unhappy Returns: One Man’s Quest To Turn Around The Most \nUnpopular Organization in America. Boston, MA: Harvard Business School Press.\nSahai, Swaiti. (2020). “Measuring Customer Experience Beyond NPS.” Pointillist. https://www.\npointillist.com/blog/how-to-measure-customer-experience-beyond-nps/. Published 04 August \n2020\nSamsung Electronics. (2017). Sustainability Report Inspire the World; Create the Future. \nCorporate Sustainability Management Office, Corporate Communications Team, Samsung \nElectronics. Seoul, Korea. \nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "251\nInternal Revenue Service \| Taxpayer First Act\nSoloman, Micah. “How These 3 Companies Improved Their Customer Experience By Working \nOn (Not In) Their Businesses.” Forbes. 24 June 2018, https://www.forbes.com/sites/\nmicahsolomon/2018/06/24/how-3-businesses-improved-the-customer-experience-by-\nworking-on-their-businesses-not-just-in-them/#4456ad2b4440. Accessed 18 Nov. 2019 \nSchoeller, Art. (2019). Design Your Contact Center to Be Customer-Centric Strategic Plan: The \nContact Centers for Customer Service Playbook. Cambridge, MA: Forrester Research, Inc. \nSebastian, Ina M., & Mocker, Martin, & Ross, Jeanne W., & Moloney, Kate G., & Beath, Cynthia \nM., & Fonstad, Mils O. (2017). MIS Quarterly Executive: How Big Old Companies Navigate \nDigital Transformation. Minneapolis, MN: University of Minnesota\nShellhammer, Alex. “How can you improve your organization’s data strategy?” Google Ad \nManager. 8 July 2019, https://blog.google/products/admanager/how-can-you-improve-your-\norganizations-data-strategy. Accessed 22 Nov. 2019\nStern, Samuel. (2019). Five Key Steps for Making Your Culture More Customer-Centric: \nBeginner Level: Culture Practices for CX Transformation. Cambridge, MA: Forrester \nResearch, Inc. \nStern, Samuel. (2018). Three Culture Practices for Long-Term Customer Centricity: Advanced \nLevel: Culture Practices for CX Transformation. Cambridge, MA: Forrester Research, Inc. \nStern, Samuel. (2018). Remove Barriers and Add Enablers for A Customer-Centric Culture \nIntermediate Level: Culture Practices for CX Transformation. Cambridge, MA: Forrester \nResearch, Inc. \nSzatvanyi, Gerard. “The Rise Of The Chief Experience Officer.” Forbes. 4 Sept. 2019 https://\nwww.forbes.com/sites/forbestechcouncil/2019/09/04/the-rise-of-the-chief-experience-\nofficer/#56a16aa32170. Accessed 14 Aug. 2020\nTaxpayer Advocacy Panel. “About Us”. https://www.irs.gov/advocate/taxpayer-advocacy-\npanel#:~:text=About Us,programs%2C products%2C and services. Accessed 10 Aug. 2020.\nTaxpayer Advocacy Service. “About TAS”. https://taxpayeradvocate.irs.gov/about-tas. Accessed \n10 Aug. 2020.\nTaxpayer First Act, Pub. L. No. 116-25 (2019)\nThe MITRE Corporation. (2019). TE/GE and the Customer Experience. Washington, D.C.: Author\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "252\nInternal Revenue Service \| Taxpayer First Act\nThe MITRE Corporation. (2019). TE/GE Mapping Customer Interaction: July 2019 IESC Update. \nWashington, D.C.: Author\nThe MITRE Corporation. (2019). Customer Experience from Assessment to Action: MITRE \nWorkshop in Support of Cross-Agency Priority Goal 4. Washington, D.C.: Authors\nToma, Andrew & Keenan, Perry & Shanahan, Mike & Dyer, Andrew & Noakes, Brad & \nBaier, Jens & Roghe, Fabrice & Dymond, Lisa & Chim, Lindsay & Kilmann, Julie. (2011). \nTechnology-Enabled Reorganization: Unlocking the Full Potential of Organizational \nTransformation. Boston, MA: Boston Consulting Group \nTowell, Noel. “ATO gets out of the compliance business.” The Sydney Morning Herald. 2 Feb. \n2016, https://www.smh.com.au/public-service/ato-gets-out-of-the-compliance-business-\n20160201-gmiu56.html. Accessed 14 Aug. 2020 \nTreasury Inspector General for Tax Administration. “About TIGTA”. https://www.treasury.gov/\ntigta/about.shtml. Accessed 10 Aug. 2020.\nTruog, David. (2018). Why and How to Lead A CX Transformation: The Executive Overview of \nThe CX Transformation Playbook. Cambridge, MA: Forrester Research, Inc.\nU.S. General Services Administration: Office of the Chief Financial Officer. (2018). Case Study: \nOrganizational Transformation: Low-Value to High-Value Services. Washington, D.C.: Author\nUseem, Michael. “How Well-Run Boards Make Decisions.” Harvard Business Review. November \n2006, https://hbr.org/2006/11/how-well-run-boards-make-decisions Accessed 10 Aug. 2020\nVermeulen, Freek. “How To Break Down The Silos In Your Firm.” Forbes 12 Feb. 2018, https://\nwww.forbes.com/sites/freekvermeulen/2018/02/12/how-to-break-down-the-silos-in-your-\nfrm/#4896d16768f6. Accessed 18 Nov. 2019\nVoster, Wam. “Survey Analysis: Information Security Governance.” Gartner. 06 Feb 2020, \nhttps://www.gartner.com/en/document/3980656/survey-analysis-information-\nsecurity-governance. Accessed 4 August 2020.\nWagenen, Juliet. (2020). What Is a Chief Data Officer? Vernon Hills, IL.: BizTech. Accessed 14 \nAug 2020.\nWhite, James. (1999). IRS Management: Formidable Challenges Confront IRS as It Attempts to \nmodernize. United States General Accounting Office. \nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "253\nInternal Revenue Service \| Taxpayer First Act\nWebster, The Honorable William H. (1999). Review of the Internal Revenue Service’s Criminal \nInvestigation Division. Washington, D.C.: Internal Revenue Service.\nWiles, Jackie. “Is It Time to Toss Out Your Old Employee Engagement Survey? – Smarter With \nGartner.” Gartner. 26 Nov 2019, https://www.gartner.com/smarterwithgartner/is-it-time-to-\ntoss-out-your-old-employee-engagement-survey. Accessed 4 Aug. 2020\nYohn, Denise Lee. (2018). “6 Ways to Build a Customer-Centric Culture.” Harvard Business \nReview. 2 Oct. 2018, https://hbr.org/2018/10/6-ways-to-build-a-customer-centric-culture. \nAccessed 17 Aug. 2020 \nZetlin, Minda. “What’s the difference between a chief data officer, chief digital officer, and chief \nanalytics officer?” CIO. 13 Nov. 2017, https://www.cio.com/article/3236476/chief-data-officer-\nvs-chief-digital-officer-vs-chief-analytics-officer.html. 19 Aug. 2020\nBIBLIOGRAPHY\n5.0 \| TAXPAYER EXPERIENCE STRATEGY\nBIBLIOGRAPHY\n", "1.0 \| COMMISSIONER’S WELCOME\n2\n5\n4\nInternal Revenue Service \| Taxpayer First Act \n2\n5\n4\nInternal Revenue Service \| Taxpayer First Act \n1.0 \| COMMISSIONER’S WELCOME\n In every interaction, \nwe need to be thinking about \nthe taxpayer and how to work \nwith them. Every interaction with \neach and every taxpayer and \nrepresentative is important on \nboth an individual and a global \nbasis. Providing high-quality, \npersonalized service is a critical \ncomponent in helping \ntaxpayers understand and \ncomply with their fling and \nreporting obligations.\n— Charles Rettig\nIRS Commissioner\n" ]
p4857.pdf	1220 Publ 4857 (PDF)	https://www.irs.gov/pub/irs-pdf/p4857.pdf	[ "ITIN\nTop (10) Reasons Why Your Form W-7 \nIs Suspended or Rejected\nThis list represents frequently encountered errors that \ncause a Form W-7 to be suspended or rejected. It is for \nuse as a reminder for Acceptance Agents (certifying and \nnon-certifying) and Tax Professionals to review the client’s \nForm W-7 for accuracy and completeness before mailing to \nAustin ITIN Operations.\nDiez (10) Razones Principales \npor las cuales su Formulario W-7(SP) \nse Suspende o se Rechaza\nEsta lista representa los errores encontrados con \nfrecuencia que causan que un Formulario W-7(SP), \nSolicitud de Número de Identificación Personal del \nContribuyente del Servicio de Impuestos Internos (ITIN, \npor sus siglas en inglés), se suspenda o se rechace. \nEs para su uso como un recordatorio para los Agentes \nTramitadores (certificantes y no certificantes) y los \nProfesionales de Impuestos para revisar el Formulario \nW-7(SP) del cliente para la exactitud y precisión antes de\nenviarlo por correo al Centro de Operaciones del Programa\nITIN en Austin.\n", "The frequently encountered errors are:\n Supporting identification documentation is \nunacceptable. Identification documentation must \nbe on the list of thirteen (13) acceptable documents \nto prove identity and foreign status. All documents \nmust be current (unexpired).\n Form W-7 (COA), Certificate of Accuracy for IRS ITIN, \nwas not attached. A valid COA must be attached to each\nW-7 submitted by a Certifying Acceptance Agent (CAA).\n Supporting identification documentation is not \noriginal or certified. Identification documentation must \nbe original documents or certified copies from the issuing \nagency. CAAs can certify all documents for primary and \nsecondary applicants except for foreign military identification \ncard, as well as passports and birth certificates for dependents.\n \nSignature is missing or invalid. If under age 18, Form W-7 \nmay be signed by the applicant, a parent, court-appointed \nguardian (court documents required), or representative (valid \npower of attorney required). Besides the applicant, only a \nparent, court-appointed guardian or a representative with \na valid power of attorney can sign. If an applicant is 18 years \nof age or older, the applicant or a court appointed guardian \ncan sign or appoint a parent or another individual to sign. The \nindividual (if other than the applicant) must type or print their \nname in the space provided and check the appropriate box that \nindicates their relationship to the applicant. If the individual is \nsigning as a court-appointed guardian, a copy of the court-\nappointment papers showing the legal guardianship must \nbe attached. Individuals other than the applicant or a court-\nappointed guardian must attach a Form 2848 from the applicant \nor court-appointed guardian authorizing them to sign the Form \nW-7\n.\n Supporting identification documentation is missing. If a \npassport is not submitted, a combination of two acceptable \ndocuments must be submitted to prove identity and foreign \nstatus. Applicants claimed as dependents on returns must \nalso prove U.S. residency if the passport doesn’t have a \ndate of entry, unless the applicant is a dependent of U.S.\nmilitary personnel stationed overseas.\n Line 6d, Date of entry into the U.S. is missing. When \nrequired, the date of entry into the U.S. must contain the \ncomplete date on which the applicant entered the country \nfor the purpose for which the ITIN is being requested.\n Line 3, Foreign address is missing. If reason “b” is \nselected on Form W-7\n, a complete foreign address is \nrequired on Line 3. Otherwise, at a minimum, applicants \nmust enter their foreign country of origin.\n \nLine 6a, Country of citizenship is missing. The complete \nname of the country or countries (in the case of dual \ncitizenship) of which the applicant is a citizen must be \nentered. Do not abbreviate country names.\n \nName and/or TIN of U.S. person is missing. If reason “d” \nor “e” is selected on Form W-7\n, the full name and TIN (SSN \nor ITIN) of the U.S. citizen or resident alien must be entered in \nthe space provided to the right.\n \nLines 6e/6f, Previously issued ITIN and name do not \nmatch IRS records. When renewing an ITIN, the ITIN and \nthe name under which it was issued must be entered in \nthe spaces provided. If the applicant’s legal name changed \nsince the ITIN was issued, documentation such as a \nmarriage certificate or court order must be attached to Form \nW-7 to support the name change.\nSee the Instructions for Form W-7 or Publication 1915, \nUnderstanding Your IRS ITIN, for more information. These products \nare available in the Forms and Publications section of IRS.gov.\n", "Los errores encontrados con frecuencia son: \n La documentación de identificación comprobatoria es \ninaceptable. La documentación de identificación tiene que \nestar en la lista de trece (13) documentos aceptables para \nprobar la identidad y la condición de extranjero. Todos los \ndocumentos tienen que estar vigentes (no vencidos). \n \nEl Formulario W-7 (COA), Certificado de Exactitud (COA, \npor sus siglas en inglés) para el ITIN del IRS, no estaba \nadjunto. Se tiene que adjuntar un COA válido a cada W-7(SP) \npresentado por un Agente Tramitador Certificante (CAA, por \nsus siglas en inglés). \n \nLa documentación de identificación comprobatoria no es \noriginal o certificada. La documentación de identificación \ntiene que ser documentos originales o copias certificadas \nde la agencia emisora. Los CAA pueden certificar todos los \ndocumentos para los solicitantes primarios y secundarios \nexcepto la tarjeta de identificación militar extranjera, así como \nlos pasaportes y actas de nacimiento para los dependientes. \n La firma falta o no es válida. Si es menor de 18 años \nde edad, el Formulario W-7(SP) puede ser firmado por el \nsolicitante, uno de los padres, un tutor designado por el tribunal \n(se requieren los documentos judiciales) o un representante \n(se requiere un poder legal válido). Además del solicitante, \nsolamente uno de los padres, un tutor designado por el \ntribunal, o un representante con un poder legal válido puede \nfirmar. Si un solicitante tiene 18 años de edad o más, el \nsolicitante o un tutor designado por el tribunal puede firmar o \ndesignar a uno de los padres u otra persona para que firme. \nLa persona (que no sea el solicitante) tiene que escribir su \nnombre en letra de molde en el espacio proporcionado y \nmarcar la casilla correspondiente que indica su parentesco con \nel solicitante. Si la persona firma como un tutor designado por \nel tribunal, se tiene que adjuntar una copia de los documentos \nde designación del tribunal que muestren la tutela legal. Las \npersonas que no sean el solicitante o un tutor designado por \nel tribunal tienen que adjuntar un Formulario 2848(SP) del \nsolicitante o del tutor designado por el tribunal que los autoriza \na firmar el Formulario W-7(SP). \n \nLa documentación de identificación comprobatoria falta. \nSi no se presenta un pasaporte, se debe presentar una \ncombinación de dos documentos aceptables para comprobar \nla identidad y la condición de extranjero. Los solicitantes \nreclamados como dependientes en las declaraciones de \nimpuestos también tienen que comprobar su residencia en los \nEstados Unidos si el pasaporte no tiene una fecha de entrada, \na menos que el solicitante sea un dependiente de personal \nmilitar estadounidense estacionado en el extranjero.\n \nLínea 6d, falta la fecha de entrada a los Estados Unidos. \nCuando sea requerido, la fecha de entrada a los Estados \nUnidos debe contener la fecha completa en la que el solicitante \ningresó al país para el propósito para el cual se solicita el ITIN. \n \nLínea 3, falta la dirección extranjera. Si se selecciona la \nrazón “b” en el Formulario W-7(SP), se requiere una dirección \nextranjera completa en la Línea 3. De lo contrario, como \nmínimo, los solicitantes tienen que anotar su país de origen \nextranjero. \n \nLínea 6a, falta el país de ciudadanía. Tiene que anotar el \nnombre completo del país o de los países (en el caso de la \ndoble ciudadanía) del que es ciudadano el solicitante. No \nabrevie los nombres de países. \n \nEl nombre y/o el TIN de la persona estadounidense falta. \nSi se selecciona la razón “d” o “e” en el Formulario W-7(SP), \nel nombre completo y el TIN (SSN o ITIN) del ciudadano o \nextranjero residente estadounidense debe anotarse en el \nespacio proporcionado a la derecha. \n \nLíneas 6e/6f, el ITIN emitido anteriormente y el nombre no \ncoinciden con los registros del IRS. Al renovar un ITIN, el \nITIN y el nombre bajo el cual se emitió tienen que anotarse en \nlos espacios proporcionados. Si el nombre legal del solicitante \ncambió desde que se emitió el ITIN, la documentación como \nun certificado de matrimonio o una orden del tribunal, tiene que \nadjuntarse al Formulario W-7(SP) para respaldar el cambio de \nnombre. \nConsulte las Instrucciones para el Formulario W-7(SP) o la \nPublicación 1915(SP), Información para Entender su Número de \nIdentificación Personal del Contribuyente (ITIN) del IRS, para obtener \nmás información. Estos productos están disponibles en la sección de \nFormularios y Publicaciones en IRS.gov/espanol.\n", "For more information on how to complete Form W-7\nand the required supporting identification and\nsupplemental documentation, visit www.irs.gov/itin.\nSpanish-speaking applicants can find this information\nat https://www.irs.gov/es/spanish and search ITIN.\nNote: Visit www.irs.gov/itinagents for information\non major changes to the Acceptance Agent program\nand how to apply if you are a renewing Agent or a tax\nprofessional interested in the program.\nComments and Suggestions\nWe value and appreciate your comments and\nsuggestions. Send them by email to \[email protected] or write to \nIRS ITIN Policy Section MS 97WI, \n401 W. Peachtree St NW, Atlanta GA 30308\nPara obtener más información sobre cómo completar\nel Formulario W-7(SP) y la documentación de respaldo y\ncomplementaria de identificación requerida, visite\nhttps://www.irs.gov/es/spanish y busque ITIN.\nNota: Visite https://www.irs.gov/es/spanish para \nobtener información sobre los cambios importantes en el\nPrograma de Agente Tramitador y cómo solicitar\nsi usted es un Agente Tramitador renovador o un\nprofesional de impuestos interesado en el programa.\nComentarios y Sugerencias\nValoramos y agradecemos sus comentarios y\nsugerencias. Envíelos por correo electrónico a\[email protected] o escriba al \nIRS ITIN Policy Section MS 97WI, \n401 W. Peachtree St NW, Atlanta GA 30308.\nPublication 4857 (en-sp) (Rev. 12-2020) Catalog Number 55009Z\nDepartment of the Treasury Internal Revenue Service www.irs.gov\nPreviously identified as Publication 4857\n" ]
p529.pdf	1220 Publ 529 (PDF)	https://www.irs.gov/pub/irs-pdf/p529.pdf	[ "Department of the Treasury\nInternal Revenue Service\nPublication 529\n(Rev. December 2020)\nCat. No. 15056O\nMiscellaneous\nDeductions\nGet forms and other information faster and easier at:\n• IRS.gov (English) \n• IRS.gov/Spanish (Español) \n• IRS.gov/Chinese (中文) \n• IRS.gov/Korean (한국어) \n• IRS.gov/Russian (Pусский) \n• IRS.gov/Vietnamese (TiếngViệt) \nContents\nReminders\n. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1\nIntroduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1\nDeductions for Unreimbursed Employee \nExpenses . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2\nUnreimbursed Employee Expenses . . . . . . . . . . . 2\nExpenses You Can’t Deduct . . . . . . . . . . . . . . . . . . 3\nMiscellaneous Deductions Subject to the 2% \nAGI Limit\n. . . . . . . . . . . . . . . . . . . . . . . . . . . . 4\nNondeductible Expenses\n. . . . . . . . . . . . . . . . . . 6\nExpenses You Can Deduct . . . . . . . . . . . . . . . . . . . 9\nHow To Report . . . . . . . . . . . . . . . . . . . . . . . . . . . 11\nExample\n. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12\nHow To Get Tax Help\n. . . . . . . . . . . . . . . . . . . . . . 12\nIndex\n. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17\nReminders\nFuture developments. For the latest information about \ndevelopments related to Pub. 529, such as legislation \nenacted after it was published, go to IRS.gov/Pub529.\nPhotographs of missing children. The IRS is a proud \npartner with the National Center for Missing & Exploited \nChildren® (NCMEC). Photographs of missing children se-\nlected by the Center may appear in this publication on pa-\nges that would otherwise be blank. You can help bring \nthese children home by looking at the photographs and \ncalling 1-800-THE-LOST (1-800-843-5678) if you recog-\nnize a child.\nIntroduction\nThis publication explains that you can no longer claim any \nmiscellaneous itemized deductions, unless you fall into \none of the qualified categories of employment claiming a \ndeduction relating to unreimbursed employee expenses. \nMiscellaneous itemized deductions are those deductions \nthat would have been subject to the 2%-of-adjus-\nted-gross-income (AGI) limitation. You can still claim cer-\ntain expenses as itemized deductions on Schedule A \n(Form 1040), Schedule A (1040-NR), or as an adjustment \nto income on Form 1040 or 1040-SR. This publication \ncovers the following topics.\n• Deductions for Unreimbursed Employee Expenses.\n• Expenses you can't deduct.\n• Expenses you can deduct.\n• How to report your deductions.\nNote. Generally, nonresident aliens who fall into one of \nthe qualified categories of employment are allowed de-\nductions to the extent they are directly related to income \nJan 04, 2021\n", "which is effectively connected with the conduct of a trade \nor business within the United States.\nYou must keep records to verify your deductions. \nYou should keep receipts, canceled checks, sub-\nstitute checks, financial account statements, and \nother documentary evidence.\nComments and suggestions. We welcome your com-\nments about this publication and suggestions for future \neditions.\nYou can send us comments through IRS.gov/\nFormComments. Or, you can write to the Internal Reve-\nnue Service, Tax Forms and Publications, 1111 Constitu-\ntion Ave. NW, IR-6526, Washington, DC 20224.\nAlthough we can’t respond individually to each com-\nment received, we do appreciate your feedback and will \nconsider your comments and suggestions as we revise \nour tax forms, instructions, and publications. Do not send \ntax questions, tax returns, or payments to the above ad-\ndress.\nGetting answers to your tax questions. If you have \na tax question not answered by this publication or the How \nTo Get Tax Help section at the end of this publication, go \nto the IRS Interactive Tax Assistant page at IRS.gov/\nHelp/ITA where you can find topics by using the search \nfeature or viewing the categories listed.\nGetting tax forms, instructions, and publications. \nVisit IRS.gov/Forms to download current and prior-year \nforms, instructions, and publications.\nOrdering tax forms, instructions, and publications. \nGo to IRS.gov/OrderForms to order current forms, instruc-\ntions, and publications; call 800-829-3676 to order \nprior-year forms and instructions. The IRS will process \nyour order for forms and publications as soon as possible. \nDo not resubmit requests you’ve already sent us. You can \nget forms and publications faster online.\nUseful Items\nYou may want to see:\nPublication\n463 Travel, Gift, and Car Expenses\n525 Taxable and Nontaxable Income\n535 Business Expenses\n587 Business Use of Your Home (Including Use by \nDaycare Providers)\n946 How To Depreciate Property\nForm (and Instructions)\nSchedule A (Form 1040) Itemized Deductions\nSchedule A (Form 1040-NR) Itemized Deductions\n2106 Employee Business Expenses\nSee How To Get Tax Help at the end of this publication for \ninformation about getting these publications and forms.\nRECORDS\n 463\n 525\n 535\n 587\n 946\n Schedule A (Form 1040)\n Schedule A (Form 1040-NR)\n 2106\nDeductions for Unreimbursed \nEmployee Expenses\nYou can no longer claim any miscellaneous itemized de-\nductions that are subject to the 2%-of-AGI limitation, in-\ncluding unreimbursed employee expenses. However, you \nmay be able to deduct certain unreimbursed employee \nbusiness expenses if you fall into one of the following cat-\negories of employment listed under Unreimbursed Em-\nployee Expenses next, or are an eligible educator as de-\nfined under Educator Expenses, later.\nUnreimbursed Employee Expenses\nYou can no longer claim a deduction for unreimbursed \nemployee expenses unless you fall into one of the follow-\ning categories of employment, or have certain qualified \neducator expenses.\n• Armed Forces reservists.\n• Qualified performing artists.\n• Fee-basis state or local government officials.\n• Employees with impairment-related work expenses.\nUnreimbursed employee expenses for individuals in \nthese categories of employment are deducted as adjust-\nments to gross income. Qualified employees listed in one \nof the categories above must complete Form 2106 to take \nthe deduction. Certain qualified educator expenses are \nalso deducted as an adjustment to gross income but you \nare not required to complete Form 2106.\nYou can deduct only unreimbursed employee expen-\nses that are paid or incurred during your tax year, for car-\nrying on your trade or business of being an employee, and \nordinary and necessary.\nAn expense is ordinary if it is common and accepted in \nyour trade, business, or profession. An expense is neces-\nsary if it is appropriate and helpful to your business. An \nexpense doesn't have to be required to be considered \nnecessary.\nCategories of Employment\nYou can deduct unreimbursed employee expenses only if \nyou qualify as an Armed Forces reservist, a qualified per-\nforming artist, a fee-basis state or local government offi-\ncial, or an employee with impairment-related work expen-\nses.\nArmed Forces reservist (member of a reserve com-\nponent). You are a member of a reserve component of \nthe Armed Forces of the United States if you are in the \nArmy, Navy, Marine Corps, Air Force, or Coast Guard Re-\nserve; the Army National Guard of the United States; or \nthe Reserve Corps of the Public Health Service.\nArmed Forces reservists traveling more than 100 \nmiles from home. If you are a member of a reserve \nPage 2 \nPublication 529 (December 2020)\n", "component of the Armed Forces of the United States and \nyou travel more than 100 miles away from home in con-\nnection with your performance of services as a member of \nthe reserves, you can deduct some of your travel expen-\nses as an adjustment to gross income. The amount of ex-\npenses you can deduct as an adjustment to gross income \nis limited to the regular federal per diem rate (for lodging, \nmeals, and incidental expenses) and the standard mile-\nage rate (for car expenses) plus any parking fees, ferry \nfees, and tolls. The balance, if any, is reported on Sched-\nule A.\nFor more information on travel expenses, see Pub. \n463.\nQualified performing artist. You are a qualified per-\nforming artist if you:\n1. Performed services in the performing arts as an em-\nployee for at least two employers during the tax year,\n2. Received from at least two of the employers wages of \n$200 or more per employer,\n3. Had allowable business expenses attributable to the \nperforming arts of more than 10% of gross income \nfrom the performing arts, and\n4. Had adjusted gross income of $16,000 or less before \ndeducting expenses as a performing artist.\nIf you are a qualified performing artist, you can deduct \nyour employee business expenses as an adjustment to in-\ncome rather than as a miscellaneous itemized deduction. \nFor example, musicians and entertainers can deduct the \ncost of theatrical clothing and accessories that aren't suit-\nable for everyday wear. If you are an employee, complete \nForm 2106. See Pub. 463 for more information.\nFee-basis state or local government official. You are \na qualifying fee-basis official if you are employed by a \nstate or political subdivision of a state and are compensa-\nted, in whole or in part, on a fee basis.\nIf you are a fee-basis official, you can claim your expen-\nses in performing services in that job as an adjustment to \nincome rather than as a miscellaneous itemized deduc-\ntion. See Pub. 463 for more information.\nEmployee with impairment-related work expenses. \nImpairment-related work expenses are the allowable ex-\npenses of an individual with physical or mental disabilities \nfor attendant care at his or her place of employment. They \nalso include other expenses in connection with the place \nof employment that enable the employee to work. See \nPub. 463 for more details.\nIf you have a physical or mental disability that limits \nyour being employed, or substantially limits one or more of \nyour major life activities, such as performing manual \ntasks, walking, speaking, breathing, learning, and work-\ning, you can deduct your impairment-related work expen-\nses.\nImpairment-related work expenses are ordinary and \nnecessary business expenses for attendant care services \nat your place of work and other expenses in connection \nwith your place of work that are necessary for you to be \nable to work.\nEducator Expenses\nIf you were an eligible educator for the tax year, you may \nbe able to deduct qualified expenses you paid as an ad-\njustment to gross income on your Schedule 1 (Form \n1040), rather than as a miscellaneous itemized deduction. \nSee the Instructions for Forms 1040 and 1040-SR for \nmore information.\nEligible educator. An eligible educator is a kindergarten \nthrough grade 12 teacher, instructor, counselor, principal, \nor aide in school for at least 900 hours during a school \nyear.\nQualified expenses. Qualified expenses include ordi-\nnary and necessary expenses paid in connection with \nbooks, supplies, equipment (including computer equip-\nment, software, and services), and other materials used in \nthe classroom. An ordinary expense is one that is com-\nmon and accepted in your educational field. A necessary \nexpense is one that is helpful and appropriate for your \nprofession as an educator. An expense doesn’t have to be \nrequired to be considered necessary.\nQualified expenses also include those expenses you \nincur while participating in professional development cour-\nses related to the curriculum in which you provide instruc-\ntion. It also includes those expenses related to those stu-\ndents for whom you provide that instruction.\nQualified expenses don’t include expenses for home \nschooling or for nonathletic supplies for courses in health \nor physical education. You must reduce your qualified ex-\npenses by the following amounts.\n• Excludable U.S. series EE and I savings bond interest \nfrom Form 8815.\n• Nontaxable qualified state tuition program earnings.\n• Nontaxable earnings from Coverdell education sav-\nings accounts.\n• Any reimbursements you received for those expenses \nthat weren’t reported to you on your Form W-2, box 1.\nExpenses You Can’t Deduct\nIn addition to the expenses that are no longer deductible \nas a miscellaneous itemized deduction, there are expen-\nses that are traditionally nondeductible under the Internal \nRevenue Code. Both categories of deduction are dis-\ncussed next.\nPublication 529 (December 2020)\n Page 3\n", "Miscellaneous Deductions Subject to \nthe 2% AGI Limit\nUnless you qualify for an exception, you generally can't \ndeduct the following expenses, even if you fall into one of \nthe qualified categories of employment listed earlier.\n• Appraisal fees for a casualty loss or charitable contri-\nbution.\n• Casualty and theft losses from property used in per-\nforming services as an employee.\n• Clerical help and office rent in caring for investments.\n• Credit or debit card convenience fees.\n• Depreciation on home computers used for invest-\nments.\n• Fees to collect interest and dividends.\n• Hobby expenses, but generally not more than hobby \nincome.\n• Indirect miscellaneous deductions from pass-through \nentities.\n• Investment fees and expenses.\n• Legal fees related to producing or collecting taxable \nincome or getting tax advice.\n• Loss on deposits in an insolvent or bankrupt financial \ninstitution.\n• Loss on traditional IRAs or Roth IRAs, when all \namounts have been distributed to you.\n• Repayments of income.\n• Repayments of social security benefits.\n• Safe deposit box rental, except for storing jewelry and \nother personal effects.\n• Service charges on dividend reinvestment plans.\n• Tax advice fees.\n• Trustee's fees for your IRA, if separately billed and \npaid.\nAppraisal Fees\nAppraisal fees you pay to figure a casualty loss or the fair \nmarket value of donated property are miscellaneous item-\nized deductions and can no longer be deducted.\nCasualty and Theft Losses\nDamaged or stolen property used in performing services \nas an employee is a miscellaneous deduction and can no \nlonger be deducted. For more information on casualty and \ntheft losses, see Pub. 547, Casualties, Disasters, and \nThefts.\nClerical Help and Office Rent\nOffice expenses, such as rent and clerical help, you pay in \nconnection with your investments and collecting taxable \nincome on those investments are miscellaneous itemized \ndeductions and are no longer deductible.\nCredit or Debit Card Convenience Fees\nThe convenience fee charged by the card processor for \npaying your income tax (including estimated tax pay-\nments) by credit or debit card is a miscellaneous itemized \ndeduction and is no longer deductible.\nDepreciation on Home Computer\nIf you use your home computer to produce income (for ex-\nample, to manage your investments that produce taxable \nincome), the depreciation of the computer for that part of \nthe usage of the computer is a miscellaneous itemized de-\nduction and is no longer deductible.\nFees To Collect Interest and Dividends\nFees you pay to a broker, bank, trustee, or similar agent to \ncollect your taxable bond interest or dividends on shares \nof stock are miscellaneous itemized deductions and can \nno longer be deducted.\nFines or Penalties\nNo deduction is allowed for fines and penalties paid to a \ngovernment or specified nongovernmental entity for the vi-\nolation of any law except in the following situations.\n• Certain amounts that constitute restitution.\n• Certain amounts paid to come into compliance with \nthe law.\n• Amounts paid or incurred as the result of certain court \norders in which no government or specified nongo-\nvernmental agency is a party.\n• Amounts paid or incurred for taxes due.\nNondeductible amounts include an amount paid in set-\ntlement of your actual or potential liability for a fine or pen-\nalty (civil or criminal). Fines or penalties include amounts \npaid such as parking tickets, tax penalties, and penalties \ndeducted from teachers' paychecks after an illegal strike. \nNo deduction is allowed for the restitution amount or \namount paid to come into compliance with the law unless \nthe amounts are specifically identified in the settlement \nagreement or court order. Also, any amount paid or incur-\nred as reimbursement to the government for the costs of \nany investigation or litigation are nondeductible.\nHobby Expenses\nA hobby isn’t a business because it isn’t carried on to \nmake a profit. If you receive income for an activity that you \ndon’t carry out to make a profit, the expenses you pay for \nthe activity are miscellaneous itemized deductions and \ncan no longer be deducted. See Not-for-Profit Activities in \nchapter 1 of Pub. 535. You must still report the income \nyou receive on your Schedule 1 (Form 1040).\nPage 4 \nPublication 529 (December 2020)\n", "Indirect Deductions of Pass-Through \nEntities\nPass-through entities include partnerships, S corpora-\ntions, and mutual funds that aren't publicly offered. De-\nductions of pass-through entities are passed through to \nthe partners or shareholders. The partner’s or sharehold-\ner’s share of passed-through deductions for investment \nexpenses are miscellaneous itemized deductions and can \nno longer be deducted.\nNonpublicly offered mutual funds. These funds will \nsend you a Form 1099-DIV, or a substitute form, showing \nyour share of gross income and investment expenses. \nThe investment expenses reported on Form 1099-DIV are \na miscellaneous itemized deduction and are no longer de-\nductible.\nInvestment Fees and Expenses\nInvestment fees, custodial fees, trust administration fees, \nand other expenses you paid for managing your invest-\nments that produce taxable income are miscellaneous \nitemized deductions and are no longer deductible.\nLegal Expenses\nLegal expenses that you incur in attempting to produce or \ncollect taxable income or that you pay in connection with \nthe determination, collection, or refund of any tax are mis-\ncellaneous itemized deductions and are no longer deduc-\ntible.\nYou can deduct legal expenses that are related to \ndoing or keeping your job, such as those you paid \nto defend yourself against criminal charges aris-\ning out of your trade or business.\nYou can deduct expenses of resolving tax issues relat-\ning to profit or loss from business reported on Schedule C \n(Form 1040), Profit or Loss From Business (Sole Proprie-\ntorship), from rentals or royalties reported on Schedule E \n(Form 1040), Supplemental Income and Loss, or from \nfarm income and expenses reported on Schedule F (Form \n1040), Profit or Loss From Farming, on that schedule. Ex-\npenses for resolving nonbusiness tax issues are miscella-\nneous itemized deductions and are no longer deductible.\nLoss on Deposits\nA loss on deposits can occur when a bank, credit union, or \nother financial institution becomes insolvent or bankrupt. If \nyou can reasonably estimate the amount of your loss on \nmoney you have on deposit in a financial institution that \nbecomes insolvent or bankrupt, you can generally choose \nto deduct it in the current year even though its exact \namount hasn't been finally determined.\nIf none of the deposit is federally insured, you could de-\nduct the loss as a nonbusiness bad debt. Report it on your \nSchedule D (Form 1040). You can no longer deduct the \nTIP\nloss as an ordinary loss or as a casualty loss on your \nSchedule A (Form 1040).\nLoss on IRA\nA loss on your traditional IRA (or Roth IRA) investment is \na miscellaneous itemized deduction and can no longer be \ndeducted.\nRepayments of Income\nGenerally, repayments of amounts that you included in in-\ncome in an earlier year is a miscellaneous itemized de-\nduction and can no longer be deducted. If you had to re-\npay more than $3,000 that you included in your income in \nan earlier year, you may be able to deduct the amount. \nSee Repayments Under Claim of Right, later.\nRepayments of Social Security Benefits\nIf the total amount shown in box 5 of all of your Forms \nSSA-1099 and RRB-1099 is a negative figure, you may be \nable to deduct part of this negative figure if the figure is \nmore than $3,000. If the figure is less than $3,000, it is a \nmiscellaneous itemized deduction and can no longer be \ndeducted. See Pub. 915, Social Security and Equivalent \nRailroad Retirement Benefits, for additional information.\nSafe Deposit Box Rent\nRent you pay for a safe deposit box you use to store taxa-\nble income-producing stocks, bonds, or investment rela-\nted papers is a miscellaneous itemized deduction and can \nno longer be deducted. You also can't deduct the rent if \nyou use the box for jewelry, other personal items, or \ntax-exempt securities.\nService Charges on Dividend\nReinvestment Plans\nService charges you pay as a subscriber in a dividend re-\ninvestment plan are a miscellaneous itemized deduction \nand can no longer be deducted. These service charges \ninclude payments for:\n• Holding shares acquired through a plan,\n• Collecting and reinvesting cash dividends, and\n• Keeping individual records and providing detailed \nstatements of accounts.\nTax Preparation Fees\nTax preparation fees on the return for the year in which \nyou pay them are a miscellaneous itemized deduction and \ncan no longer be deducted. These fees include the cost of \ntax preparation software programs and tax publications. \nThey also include any fee you paid for electronic filing of \nyour return.\nPublication 529 (December 2020)\n Page 5\n", "Trustee's Administrative Fees for IRA\nTrustee's administrative fees that are billed separately and \npaid by you in connection with your IRA are a miscellane-\nous itemized deduction and can no longer be deducted.\nNondeductible Expenses\nIn addition to the miscellaneous itemized deductions dis-\ncussed earlier, you can't deduct the following expenses.\nList of Nondeductible Expenses\n• Adoption expenses.\n• Broker's commissions.\n• Burial or funeral expenses, including the cost of a \ncemetery lot. \n• Campaign expenses.\n• Capital expenses.\n• Check-writing fees.\n• Club dues.\n• Commuting expenses.\n• Fees and licenses, such as car licenses, marriage li-\ncenses, and dog tags.\n• Fines or penalties.\n• Health spa expenses.\n• Hobby losses—but see Hobby Expenses, earlier.\n• Home repairs, insurance, and rent.\n• Home security system.\n• Illegal bribes and kickbacks—see Bribes and kick-\nbacks in chapter 11 of Pub. 535. \n• Investment-related seminars.\n• Life insurance premiums paid by the insured.\n• Lobbying expenses.\n• Losses from the sale of your home, furniture, personal \ncar, etc.\n• Lost or misplaced cash or property.\n• Lunches with co-workers.\n• Meals while working late.\n• Medical expenses as business expenses other than \nmedical examinations required by your employer.\n• Personal disability insurance premiums. \n• Personal legal expenses.\n• Personal, living, or family expenses.\n• Political contributions.\n• Professional accreditation fees.\n• Professional reputation improvement expenses.\n• Relief fund contributions.\n• Residential telephone line.\n• Stockholders’ meeting attendance expenses.\n• Tax-exempt income earning/collecting expenses.\n• The value of wages never received or lost vacation \ntime.\n• Travel expenses for another individual.\n• Voluntary unemployment benefit fund contributions.\n• Wristwatches. \nAdoption Expenses\nYou can't deduct the expenses of adopting a child but you \nmay be able to take a credit for those expenses. For de-\ntails, see Form 8839, Qualified Adoption Expenses.\nCommissions\nCommissions paid on the purchase of securities aren't de-\nductible, either as business or nonbusiness expenses. In-\nstead, these fees must be added to the taxpayer's cost of \nthe securities. Commissions paid on the sale are deducti-\nble as business expenses only by dealers.\nCampaign Expenses\nYou can't deduct campaign expenses of a candidate for \nany office, even if the candidate is running for reelection to \nthe office. These include qualification and registration fees \nfor primary elections.\nLegal fees. You can't deduct legal fees paid to defend \ncharges that arise from participation in a political cam-\npaign.\nCapital Expenses\nYou can't currently deduct amounts paid to buy property \nthat has a useful life substantially beyond the tax year or \namounts paid to increase the value or prolong the life of \nproperty. If you use such property in your work, you may \nbe able to take a depreciation deduction. See Pub. 946. If \nthe property is a car used in your work, also see Pub. 463.\nCheck-Writing Fees on Personal Account\nIf you have a personal checking account, you can't deduct \nfees charged by the bank for the privilege of writing \nchecks, even if the account pays interest.\nClub Dues\nGenerally, you can't deduct the cost of membership in any \nclub organized for business, pleasure, recreation, or other \nsocial purpose. This includes business, social, athletic, \nluncheon, sporting, airline, hotel, golf, and country clubs.\nYou can't deduct dues paid to an organization if one of \nits main purposes is to:\n• Conduct entertainment activities for members or their \nguests, or\nPage 6 \nPublication 529 (December 2020)\n", "• Provide members or their guests with access to enter-\ntainment facilities.\nDues paid to airline, hotel, and luncheon clubs aren't \ndeductible.\nCommuting Expenses\nYou can't deduct commuting expenses (the cost of trans-\nportation between your home and your main or regular \nplace of work). If you fall into one of the qualified catego-\nries of employment discussed under Unreimbursed Em-\nployee Expenses, earlier, and you haul tools, instruments, \nor other items in your car to and from work, you can de-\nduct only the additional cost of hauling the items, such as \nthe rent on a trailer to carry the items.\nFines or Penalties\nNo deduction is allowed for fines and penalties paid to a \ngovernment or specified nongovernmental entity for the vi-\nolation of any law except in the following situations.\n• Certain amounts that constitute restitution.\n• Certain amounts paid to come into compliance with \nthe law.\n• Amounts paid or incurred as the result of certain court \norders in which no government or specified nongo-\nvernmental agency is a party.\n• Amounts paid or incurred for taxes due.\nNondeductible amounts include an amount paid in set-\ntlement of your actual or potential liability for a fine or pen-\nalty (civil or criminal). Fines or penalties include amounts \npaid such as parking tickets, tax penalties, and penalties \ndeducted from teachers' paychecks after an illegal strike.\nNo deduction is allowed for the restitution amount or \namount paid to come into compliance with the law unless \nthe amounts are specifically identified in the settlement \nagreement or court order. Also, any amount paid or incur-\nred as reimbursement to the government for the costs of \nany investigation or litigation are nondeductible.\nHealth Spa Expenses\nYou can't deduct health spa expenses, even if there is a \njob requirement to stay in excellent physical condition, \nsuch as might be required of a law enforcement officer.\nHome Security System\nYou can't deduct the cost of a home security system as a \nmiscellaneous deduction. However, you may be able to \nclaim a deduction for a home security system as a busi-\nness expense if you have a home office. See Home Office \nunder Expenses You Can Deduct, later, and Pub. 587.\nInvestment-Related Seminars\nYou can't deduct any expenses for attending a conven-\ntion, seminar, or similar meeting for investment purposes.\nLife Insurance Premiums\nYou can't deduct premiums you pay on your life insur-\nance. You may be able to deduct, as alimony, premiums \nyou pay on life insurance policies assigned to your former \nspouse. See Pub. 504, Divorced or Separated Individuals, \nfor information on alimony.\nLobbying Expenses\nYou generally can't deduct amounts paid or incurred for \nlobbying expenses. These include expenses to:\n1. Influence legislation;\n2. Participate, or intervene, in any political campaign for, \nor against, any candidate for public office;\n3. Attempt to influence the general public, or segments \nof the public, about elections, legislative matters, or \nreferendums; or\n4. Communicate directly with covered executive branch \nofficials in any attempt to influence the official actions \nor positions of those officials.\nLobbying expenses also include any amounts paid or \nincurred for research, preparation, planning, or coordina-\ntion of any of these activities.\nCovered executive branch official. A covered execu-\ntive branch official, for the purpose of (4) above, is any of \nthe following officials.\n• The President.\n• The Vice President.\n• Any officer or employee of the White House Office of \nthe Executive Office of the President, and the two \nmost senior level officers of each of the other agen-\ncies in the Executive Office.\n• Any individual serving in a position in Level I of the Ex-\necutive Schedule under section 5312 of title 5, United \nStates Code, any other individual designated by the \nPresident as having Cabinet-level status, and any im-\nmediate deputy of one of these individuals.\nDues used for lobbying. If a tax-exempt organization \nnotifies you that part of the dues or other amounts you pay \nto the organization are used to pay nondeductible lobby-\ning expenses, you can't deduct that part.\nExceptions. You can deduct certain lobbying expenses \nif they are ordinary and necessary expenses of carrying \non your trade or business.\n• You can deduct in-house expenses for influencing \nlegislation or communicating directly with a covered \nexecutive branch official if the expenses for the tax \nPublication 529 (December 2020)\n Page 7\n", "year aren't more than $2,000 (not counting overhead \nexpenses).\n• If you are a professional lobbyist, you can deduct the \nexpenses you incur in the trade or business of lobby-\ning on behalf of another person. Payments by the \nother person to you for lobbying activities can't be de-\nducted. \nLost or Mislaid Cash or Property\nYou can't deduct a loss based on the mere disappearance \nof money or property. However, an accidental loss or dis-\nappearance of property can qualify as a casualty if it re-\nsults from an identifiable event that is sudden, unexpec-\nted, or unusual. See Pub. 547.\nLunches With Co-Workers\nYou can't deduct the expenses of lunches with co-work-\ners, except while traveling away from home on business. \nSee Pub. 463 for information on deductible expenses \nwhile traveling away from home.\nMeals While Working Late\nYou can't deduct the cost of meals while working late. \nHowever, you may be able to claim a deduction for 50% of \nthe cost of the meals if you are traveling away from home. \nSee Pub. 463 for information on deductible expenses \nwhile traveling away from home.\nPersonal Legal Expenses\nYou can't deduct personal legal expenses such as those \nfor the following.\n• Custody of children.\n• Breach of promise to marry suit.\n• Civil or criminal charges resulting from a personal re-\nlationship.\n• Damages for personal injury (except certain whistle-\nblower claims and unlawful discrimination claims). For \nmore information about unlawful discrimination claims, \nsee Expenses You Can’t Deduct, earlier.\n• Preparation of a title (or defense or perfection of a ti-\ntle).\n• Preparation of a will.\n• Property claims or property settlement in a divorce.\nYou can't deduct these expenses even if a result of the \nlegal proceeding is the loss of income-producing property.\nPolitical Contributions\nYou can't deduct contributions made to a political candi-\ndate, a campaign committee, or a newsletter fund. Adver-\ntisements in convention bulletins and admissions to din-\nners or programs that benefit a political party or political \ncandidate aren't deductible.\nProfessional Accreditation Fees\nYou can't deduct professional accreditation fees such as \nthe following.\n• Accounting certificate fees paid for the initial right to \npractice accounting.\n• Bar exam fees and incidental expenses in securing in-\nitial admission to the bar.\n• Medical and dental license fees paid to get initial li-\ncensing.\nProfessional Reputation\nYou can't deduct expenses of radio and TV appearances \nto increase your personal prestige or establish your pro-\nfessional reputation.\nRelief Fund Contributions\nYou can't deduct contributions paid to a private plan that \npays benefits to any covered employee who can't work \nbecause of any injury or illness not related to the job.\nResidential Telephone Service\nYou can't deduct any charge (including taxes) for basic lo-\ncal telephone service for the first telephone line to your \nresidence, even if it is used in a trade or business.\nStockholders' Meetings\nYou can't deduct transportation and other expenses you \npay to attend stockholders' meetings of companies in \nwhich you own stock but have no other interest. You can't \ndeduct these expenses even if you are attending the \nmeeting to get information that would be useful in making \nfurther investments.\nTax-Exempt Income Expenses\nYou can't deduct expenses to produce tax-exempt in-\ncome. You can't deduct interest on a debt incurred or con-\ntinued to buy or carry tax-exempt securities.\nIf you have expenses to produce both taxable and \ntax-exempt income, but you can't identify the expenses \nthat produce each type of income, you must divide the ex-\npenses based on the amount of each type of income to \ndetermine the amount that you can deduct.\nTravel Expenses for Another Individual\nYou generally can't deduct travel expenses you pay or in-\ncur for a spouse, dependent, or other individual who ac-\ncompanies you (or your employee) on personal or busi-\nness travel unless the spouse, dependent, or other \nindividual is an employee of the taxpayer, the travel is for \na bona fide business purpose, and such expenses would \notherwise be deductible by the spouse, dependent, or \nPage 8 \nPublication 529 (December 2020)\n", "other individual. See Pub. 463 for more information on de-\nductible travel expenses.\nVoluntary Unemployment Benefit Fund \nContributions\nYou can't deduct voluntary unemployment benefit fund \ncontributions you make to a union fund or a private fund. \nHowever, you can deduct contributions as taxes if state \nlaw requires you to make them to a state unemployment \nfund that covers you for the loss of wages from unemploy-\nment caused by business conditions.\nWristwatches\nYou can't deduct the cost of a wristwatch, even if there is \na job requirement that you know the correct time to prop-\nerly perform your duties.\nExpenses You Can Deduct\nYou can deduct the items listed below as itemized deduc-\ntions. Report these items on your Schedule A (Form \n1040), or your Schedule A (Form 1040-NR).\nList of Deductions\n• Amortizable premium on taxable bonds.\n• Casualty and theft losses from income-producing \nproperty.\n• Excess deductions (including administrative expen-\nses) allowed a beneficiary on termination of an estate \nor trust.\n• Federal estate tax on income in respect of a dece-\ndent.\n• Fines or penalties.\n• Gambling losses up to the amount of gambling win-\nnings.\n• Impairment-related work expenses of persons with \ndisabilities.\n• Losses from Ponzi-type investment schemes.\n• Repayments of more than $3,000 under a claim of \nright.\n• Unlawful discrimination claims.\n• Unrecovered investment in an annuity.\n• An ordinary loss attributable to a contingent payment \ndebt instrument or an inflation-indexed debt instru-\nment (for example, a Treasury Inflation-Protected Se-\ncurity).\nAmortizable Premium on Taxable Bonds\nIn general, if the amount you pay for a bond is greater than \nits stated principal amount, the excess is bond premium. \nYou can elect to amortize the premium on taxable bonds. \nThe amortization of the premium is generally an offset to \ninterest income on the bond rather than a separate deduc-\ntion item.\nPre-1998 election to amortize bond premium. Gener-\nally, if you first elected to amortize bond premium before \n1998, the above treatment of the premium doesn't apply \nto bonds you acquired before 1988.\nBonds acquired after October 22, 1986, and before \n1988. The amortization of the premium on these bonds is \ninvestment interest expense subject to the investment in-\nterest limit, unless you chose to treat it as an offset to in-\nterest income on the bond.\nBonds acquired before October 23, 1986. The am-\nortization of the premium on these bonds is deducted as \nan itemized deduction on your Schedule A (Form 1040).\nDeduction for excess premium. On certain bonds \n(such as bonds that pay a variable rate of interest or that \nprovide for an interest-free period), the amount of bond \npremium allocable to a period may exceed the amount of \nstated interest allocable to the period. If this occurs, treat \nthe excess as an itemized deduction on your Schedule A \n(Form 1040). However, the amount deductible is limited to \nthe amount by which your total interest inclusions on the \nbond in prior periods exceed the total amount you treated \nas a bond premium deduction on the bond in prior peri-\nods.\nIf any of the excess bond premium can't be deducted \nbecause of the limit, this amount is carried forward to the \nnext period and is treated as bond premium allocable to \nthat period. If there is a bond premium carryforward as of \nthe end of the accrual period in which the bond is sold, re-\ntired, or otherwise disposed of, treat the carryforward as \nan itemized deduction on your Schedule A (Form 1040).\nPre-1998 choice to amortize bond premium. If \nyou made the choice to amortize the premium on \ntaxable bonds before 1998, you can deduct the \nbond premium amortization that is more than your interest \nincome only for bonds acquired during 1998 and later \nyears.\nMore information. For more information on bond pre-\nmium, see Bond Premium Amortization in chapter 3 of \nPub. 550.\nCasualty and Theft Losses of \nIncome-Producing Property\nYou can deduct a casualty or theft loss as an itemized de-\nduction on your Schedule A (Form 1040), if the damaged \nor stolen property was income-producing property (prop-\nerty held for investment, such as stocks, notes, bonds, \ngold, silver, vacant lots, and works of art). First report the \nloss on Form 4684. You may also have to include the loss \non Form 4797, Sales of Business Property, if you are oth-\nerwise required to file that form. To figure your deduction, \nadd all casualty or theft losses from this type of property \nincluded on Form 4684, or Form 4797. For more informa-\ntion on casualty and theft losses, see Pub. 547.\nCAUTION\n!\nPublication 529 (December 2020)\n Page 9\n", "Excess Deductions of an Estate or Trust\nGenerally, if an estate or trust has an excess deduction re-\nsulting from total deductions being greater than its gross \nincome, in the estate’s or trust's last tax year, a beneficiary \ncan deduct the excess deductions, depending on its char-\nacter. The excess deductions retain their character as an \nadjustment to arrive at adjusted gross income on Sched-\nule 1 (Form 1040), as a non-miscellaneous itemized de-\nduction reported on Schedule A (Form 1040), or as a mis-\ncellaneous itemized deduction. For more information on \nexcess deductions of an estate or trust, see the Instruc-\ntions for Schedule K-1 (Form 1041) for a Beneficiary Filing \nForm 1040 or 1040-SR.\nFederal Estate Tax on Income in Respect of \na Decedent\nYou can deduct the federal estate tax attributable to in-\ncome in respect of a decedent that you as a beneficiary \ninclude in your gross income. Income in respect of the de-\ncedent is gross income that the decedent would have re-\nceived had death not occurred and that wasn't properly in-\ncludible in the decedent's final income tax return. See \nPub. 559 for information about figuring the amount of this \ndeduction.\nFines or Penalties\nGenerally, a deduction is allowed for fines and penalties \npaid to a government or specified nongovernmental entity \nfor the violation of any law in the following situations.\n• Certain amounts that constitute restitution.\n• Certain amounts paid to come into compliance with \nthe law.\n• Amounts paid or incurred as the result of certain court \norders in which no government or specified nongo-\nvernmental agency is a party.\n• Amounts paid or incurred for taxes due.\nNondeductible amounts include an amount paid in set-\ntlement of your actual or potential liability for a fine or pen-\nalty (civil or criminal). Fines or penalties include amounts \npaid such as parking tickets, tax penalties, and penalties \ndeducted from teachers' paychecks after an illegal strike.\nNo deduction is allowed for the restitution amount or \namount paid to come into compliance with the law unless \nthe amounts are specifically identified in the settlement \nagreement or court order. Also, any amount paid or incur-\nred as reimbursement to the government for the costs of \nany investigation or litigation are nondeductible.\nGambling Losses Up to the Amount of \nGambling Winnings\nYou must report the full amount of your gambling winnings \nfor the year on your Schedule 1 (Form 1040). You deduct \nyour gambling losses for the year on your Schedule A \n(Form 1040). Gambling losses include the actual cost of \nwagers plus expenses incurred in connection with the \nconduct of the gambling activity, such as travel to and \nfrom a casino. You can't deduct gambling losses that are \nmore than your winnings. Generally, nonresident aliens \ncan't deduct gambling losses on your Schedule A (Form \n1040-NR).\nYou can't reduce your gambling winnings by your \ngambling losses and report the difference. You \nmust report the full amount of your winnings as in-\ncome and claim your losses (up to the amount of win-\nnings) as an itemized deduction. Therefore, your records \nshould show your winnings separately from your losses.\nDiary of winnings and losses. You must keep \nan accurate diary or similar record of your losses \nand winnings.\nYour diary should contain at least the following informa-\ntion.\n• The date and type of your specific wager or wagering \nactivity.\n• The name and address or location of the gambling es-\ntablishment.\n• The names of other persons present with you at the \ngambling establishment.\n• The amount(s) you won or lost.\nProof of winnings and losses. In addition to your diary, \nyou should also have other documentation. You can gen-\nerally prove your winnings and losses through Form \nW-2G, Certain Gambling Winnings; Form 5754, State-\nment by Person(s) Receiving Gambling Winnings; wager-\ning tickets; canceled checks; substitute checks; credit re-\ncords; bank withdrawals; and statements of actual \nwinnings or payment slips provided to you by the gam-\nbling establishment.\nFor specific wagering transactions, you can use the fol-\nlowing items to support your winnings and losses.\nThese recordkeeping suggestions are intended \nas general guidelines to help you establish your \nwinnings and losses. They aren't all-inclusive. \nYour tax liability depends on your particular facts and cir-\ncumstances.\nKeno. Copies of the keno tickets you purchased that \nwere validated by the gambling establishment, copies of \nyour casino credit records, and copies of your casino \ncheck-cashing records.\nSlot machines. A record of the machine number and \nall winnings by date and time the machine was played.\nTable games (twenty-one (blackjack), craps, \npoker, baccarat, roulette, wheel of fortune, etc.). The \nnumber of the table at which you were playing. Casino \ncredit card data indicating whether the credit was issued \nin the pit or at the cashier's cage.\nBingo. A record of the number of games played, cost \nof tickets purchased, and amounts collected on winning \nCAUTION\n!\nRECORDS\nCAUTION\n!\nPage 10 \nPublication 529 (December 2020)\n", "tickets. Supplemental records include any receipts from \nthe casino, parlor, etc.\nRacing (horse, harness, dog, etc.). A record of the \nraces, amounts of wagers, amounts collected on winning \ntickets, and amounts lost on losing tickets. Supplemental \nrecords include unredeemed tickets and payment records \nfrom the racetrack.\nLotteries. A record of ticket purchases, dates, win-\nnings, and losses. Supplemental records include unre-\ndeemed tickets, payment slips, and winnings statements.\nHome Office\nIf you use a part of your home regularly and exclusively to \nconduct business, you may be able to deduct a part of the \noperating expenses and depreciation of your home.\nYou can claim this deduction for the business use of a \npart of your home only if you use that part of your home \nregularly and exclusively:\n• As your principal place of business for any trade or \nbusiness;\n• As a place to meet or deal with your patients, clients, \nor customers in the normal course of your trade or \nbusiness; or\n• In the case of a separate structure not attached to \nyour home, in connection with your trade or business.\nPrincipal place of business. If you have more than one \nplace of business, the business part of your home is your \nprincipal place of business if:\n• You use it regularly and exclusively for administrative \nor management activities of your trade or business, \nand\n• You have no other fixed location where you conduct \nsubstantial administrative or management activities of \nyour trade or business.\nOtherwise, the location of your principal place of busi-\nness generally depends on the relative importance of the \nactivities performed at each location and the time spent at \neach location.\nYou should keep records that will give the infor-\nmation needed to figure the deduction according \nto these rules. Also keep canceled checks, sub-\nstitute checks, or account statements and receipts of the \nexpenses paid to prove the deductions you claim.\nMore information. See Pub. 587 for more detailed infor-\nmation and a worksheet for figuring the deduction.\nLosses From Ponzi-Type Investment \nSchemes\nThese losses are deductible as theft losses of in-\ncome-producing property on your tax return for the year \nthe loss was discovered. You figure the deductible loss in \nSection B of Form 4684. See the Form 4684 instructions \nRECORDS\nand Pub. 547, Casualties, Disasters, and Thefts, for more \ninformation.\nRepayments Under Claim of Right\nIf you had to repay more than $3,000 that you included in \nyour income in an earlier year because at the time you \nthought you had an unrestricted right to it, you may be \nable to deduct the amount you repaid, or take a credit \nagainst your tax. See Repayments in Pub. 525 for more \ninformation.\nUnlawful Discrimination Claims\nYou may be able to deduct, as an adjustment to income \non your Schedule 1 (Form 1040), attorney fees and court \ncosts for actions settled or decided after October 22, \n2004, involving a claim of unlawful discrimination, a claim \nagainst the U.S. Government, or a claim made under sec-\ntion 1862(b)(3)(A) of the Social Security Act. However, the \namount you can deduct on your Schedule 1 (Form 1040), \nis limited to the amount of the judgment or settlement you \nare including in income for the tax year. See Pub. 525 for \nmore information.\nUnrecovered Investment in Annuity\nA retiree who contributed to the cost of an annuity can ex-\nclude from income a part of each payment received as a \ntax-free return of the retiree's investment. If the retiree \ndies before the entire investment is recovered tax free, \nany unrecovered investment can be deducted on the retir-\nee's final income tax return. See Pub. 575, Pension and \nAnnuity Income, for more information about the tax treat-\nment of pensions and annuities.\nHow To Report\nClaim most deductions as an itemized deduction on your \nSchedule A (Form 1040), or Schedule A (Form 1040-NR). \nHowever, see Schedule 1 (Form 1040), later.\nReporting employee business expenses. As descri-\nbed earlier in Unreimbursed Employee Expenses, there \nare four categories of employees who can claim deduc-\ntions for unreimbursed employee expenses.\nEmployees in the following categories can claim their \nunreimbursed employee expenses.\n• Armed Forces reservists.\n• Qualified performing artists.\n• Fee-basis state or local government officials.\n• Employees with impairment-related work expenses.\nGenerally, nonresident aliens who fall into one of \nthe qualified categories of employment are al-\nlowed deductions to the extent they are directly \nrelated to income which is effectively connected with the \nconduct of a trade or business within the United States.\nCAUTION\n!\nPublication 529 (December 2020)\n Page 11\n", "Form 2106. If you have deductible employee business \nexpenses, you must usually file Form 2106.\nYou must file Form 2106 if any of the following applies \nto you.\n1. You are a qualified performing artist claiming perform-\ning-artist-related expenses.\n2. You are a fee-basis state or local government official \nclaiming expenses in performing that job.\n3. You are an individual with a disability and are claiming \nimpairment-related work expenses. See Employees \nwith impairment-related work expenses, later.\n4. You have travel expenses as a member of the Armed \nForces reserves that you can deduct as an adjust-\nment to gross income.\n5. You are claiming job-related vehicle, travel, transpor-\ntation, or non-entertainment meal expenses. See the \nInstructions for Form 2106 for more information.\nDepreciation. Use Form 4562, to claim the depreciation \ndeduction for a computer you placed in service after 2018. \nComplete Form 4562, if you are claiming a section 179 \ndeduction.\nDon't use Form 4562 to claim the depreciation deduc-\ntion for a computer you placed in service before 2019 and \nused only in your home office, unless you are otherwise \nrequired to file Form 4562. Instead, report the deprecia-\ntion directly on the appropriate form.\nEmployees with impairment-related work expenses. \nMost of the categories of employees who are able to claim \ndeductions for unreimbursed employees report these de-\nductions as an adjustment to income on Schedule 1 \n(Form 1040), discussed next. However, employees with \nimpairment-related work expenses on Form 2106 report \nthese expenses on Schedule A (Form 1040).\nEnter impairment-related work expenses on Form \n2106. Enter on your Schedule A (Form 1040); or your \nSchedule A (Form 1040-NR), that part of the amount on \nForm 2106, that is related to your impairment. Those em-\nployment-related expenses not related to your impairment \nare a miscellaneous itemized deduction and are no longer \ndeductible.\nIf you are self-employed, enter your impairment-related \nwork expenses on the appropriate Form (Schedule C, E, \nor F) used to report your business income and expenses.\nExample. You are blind. You must use a reader to do \nyour work. You use the reader both during your regular \nworking hours at your place of work and outside your reg-\nular working hours away from your place of work. The \nreader's services are only for your work. You can deduct \nyour expenses for the reader as impairment-related work \nexpenses.\nSchedule 1 (Form 1040)\nMost deductible employee business expenses on Form \n2106 are reported as an adjustment to income on your \nSchedule 1 (Form 1040). However, certain other expen-\nses are deducted on Schedule A (Form 1040).\nEducator expenses. Certain qualified expenses of eligi-\nble educators can be deducted on your Schedule 1 (Form \n1040).\nUnlawful discrimination claims. You can deduct cer-\ntain attorney fees and court costs for unlawful discrimina-\ntion claims, described earlier, on your Schedule 1 (Form \n1040).\nExample\nDebra Smith is an army reservist stationed 110 miles from \nher home. She makes this trip once each month. In addi-\ntion to her travel expenses, she pays for her own uniforms \nand for the cost of cleaning those uniforms.\nIn addition to her employee business expenses as an \narmy reservist, she has gambling losses from her trips to \nthe casino and race track. She has gambling winnings of \n$5,400 and gambling losses of $5,700.\nDebra completes Form 2106. She enters her transpor-\ntation expenses of $500 as a reservist and she enters the \namount of her expenses for the purchase of uniforms and \ntheir cleaning, $250. She then completes the form, enter-\ning the $750 as her total expenses. Only the transporta-\ntion expenses for travel as a reservist are deductible as an \nadjustment on her Schedule 1 (Form 1040). The $250 is a \nmiscellaneous itemized deduction and is not deductible.\nDebra claims her gambling losses that don’t exceed \nher gambling winnings as an itemized deduction. Debra \nenters her allowable loss ($5,400) on her Schedule A \n(Form 1040).\nHow To Get Tax Help\nIf you have questions about a tax issue, need help prepar-\ning your tax return, or want to download free publications, \nforms, or instructions, go to IRS.gov and find resources \nthat can help you right away.\nPreparing and filing your tax return. After receiving all \nyour wage and earnings statements (Form W-2, W-2G, \n1099-R, 1099-MISC, 1099-NEC, etc.); unemployment \ncompensation statements (by mail or in a digital format) or \nother government payment statements (Form 1099-G); \nand interest, dividend, and retirement statements from \nbanks and investment firms (Forms 1099), you have sev-\neral options to choose from to prepare and file your tax re-\nturn. You can prepare the tax return yourself, see if you \nqualify for free tax preparation, or hire a tax professional to \nprepare your return.\nFree options for tax preparation. Go to IRS.gov to see \nyour options for preparing and filing your return online or \nPage 12 \nPublication 529 (December 2020)\n", "in your local community, if you qualify, which include the \nfollowing.\n• Free File. This program lets you prepare and file your \nfederal individual income tax return for free using \nbrand-name tax-preparation-and-filing software or \nFree File fillable forms. However, state tax preparation \nmay not be available through Free File. Go to IRS.gov/\nFreeFile to see if you qualify for free online federal tax \npreparation, e-filing, and direct deposit or payment op-\ntions.\n• VITA. The Volunteer Income Tax Assistance (VITA) \nprogram offers free tax help to people with \nlow-to-moderate incomes, persons with disabilities, \nand limited-English-speaking taxpayers who need \nhelp preparing their own tax returns. Go to IRS.gov/\nVITA, download the free IRS2Go app, or call \n800-906-9887 for information on free tax return prepa-\nration.\n• TCE. The Tax Counseling for the Elderly (TCE) pro-\ngram offers free tax help for all taxpayers, particularly \nthose who are 60 years of age and older. TCE volun-\nteers specialize in answering questions about pen-\nsions and retirement-related issues unique to seniors. \nGo to IRS.gov/TCE, download the free IRS2Go app, \nor call 888-227-7669 for information on free tax return \npreparation.\n• MilTax. Members of the U.S. Armed Forces and \nqualified veterans may use MilTax, a free tax service \noffered by the Department of Defense through Military \nOneSource.\nAlso, the IRS offers Free Fillable Forms, which can \nbe completed online and then filed electronically re-\ngardless of income.\nUsing online tools to help prepare your return. Go to \nIRS.gov/Tools for the following.\n• The Earned Income Tax Credit Assistant (IRS.gov/\nEITCAssistant) determines if you’re eligible for the \nearned income credit (EIC).\n• The Online EIN Application (IRS.gov/EIN) helps you \nget an employer identification number (EIN).\n• The Tax Withholding Estimator (IRS.gov/W4app) \nmakes it easier for everyone to pay the correct amount \nof tax during the year. The tool is a convenient, online \nway to check and tailor your withholding. It’s more \nuser-friendly for taxpayers, including retirees and \nself-employed individuals. The features include the \nfollowing.\n– Easy to understand language.\n– The ability to switch between screens, correct pre-\nvious entries, and skip screens that don’t apply.\n– Tips and links to help you determine if you qualify \nfor tax credits and deductions.\n– A progress tracker.\n– A self-employment tax feature.\n– Automatic calculation of taxable social security ben-\nefits.\n• The First Time Homebuyer Credit Account Look-up \n(IRS.gov/HomeBuyer) tool provides information on \nyour repayments and account balance.\n• The Sales Tax Deduction Calculator (IRS.gov/\nSalesTax) figures the amount you can claim if you \nitemize deductions on Schedule A (Form 1040).\nGetting answers to your tax questions. On \nIRS.gov, you can get up-to-date information on \ncurrent events and changes in tax law.\n• IRS.gov/Help: A variety of tools to help you get an-\nswers to some of the most common tax questions.\n• IRS.gov/ITA: The Interactive Tax Assistant, a tool that \nwill ask you questions on a number of tax law topics \nand provide answers.\n• IRS.gov/Forms: Find forms, instructions, and publica-\ntions. You will find details on 2020 tax changes and \nhundreds of interactive links to help you find answers \nto your questions.\n• You may also be able to access tax law information in \nyour electronic filing software.\nNeed someone to prepare your tax return? There are \nvarious types of tax return preparers, including tax prepar-\ners, enrolled agents, certified public accountants (CPAs), \nattorneys, and many others who don’t have professional \ncredentials. If you choose to have someone prepare your \ntax return, choose that preparer wisely. A paid tax pre-\nparer is:\n• Primarily responsible for the overall substantive accu-\nracy of your return,\n• Required to sign the return, and\n• Required to include their preparer tax identification \nnumber (PTIN).\nAlthough the tax preparer always signs the return, \nyou're ultimately responsible for providing all the informa-\ntion required for the preparer to accurately prepare your \nreturn. Anyone paid to prepare tax returns for others \nshould have a thorough understanding of tax matters. For \nmore information on how to choose a tax preparer, go to \nTips for Choosing a Tax Preparer on IRS.gov.\nCoronavirus. Go to IRS.gov/Coronavirus for links to in-\nformation on the impact of the coronavirus, as well as tax \nrelief available for individuals and families, small and large \nbusinesses, and tax-exempt organizations.\nTax reform. Tax reform legislation affects individuals, \nbusinesses, and tax-exempt and government entities. Go \nto IRS.gov/TaxReform for information and updates on \nhow this legislation affects your taxes.\nEmployers can register to use Business Services On-\nline. The Social Security Administration (SSA) offers on-\nline service at SSA.gov/employer for fast, free, and secure \nonline W-2 filing options to CPAs, accountants, enrolled \nPublication 529 (December 2020)\n Page 13\n", "agents, and individuals who process Form W-2, Wage \nand Tax Statement, and Form W-2c, Corrected Wage and \nTax Statement.\nIRS social media. Go to IRS.gov/SocialMedia to see the \nvarious social media tools the IRS uses to share the latest \ninformation on tax changes, scam alerts, initiatives, prod-\nucts, and services. At the IRS, privacy and security are \nparamount. We use these tools to share public informa-\ntion with you. Don’t post your SSN or other confidential in-\nformation on social media sites. Always protect your iden-\ntity when using any social networking site.\nThe following IRS YouTube channels provide short, in-\nformative videos on various tax-related topics in English, \nSpanish, and ASL.\n• Youtube.com/irsvideos.\n• Youtube.com/irsvideosmultilingua.\n• Youtube.com/irsvideosASL.\nWatching \nIRS \nvideos. The \nIRS \nVideo \nportal \n(IRSVideos.gov) contains video and audio presentations \nfor individuals, small businesses, and tax professionals.\nOnline tax information in other languages. You can \nfind information on IRS.gov/MyLanguage if English isn’t \nyour native language.\nFree interpreter service. Multilingual assistance, provi-\nded by the IRS, is available at Taxpayer Assistance Cen-\nters (TACs) and other IRS offices. Over-the-phone inter-\npreter service is accessible in more than 350 languages.\nGetting tax forms and publications. Go to IRS.gov/\nForms to view, download, or print all of the forms, instruc-\ntions, and publications you may need. You can also down-\nload and view popular tax publications and instructions \n(including the Instructions for Forms 1040 and 1040-SR) \non mobile devices as an eBook at IRS.gov/eBooks. Or \nyou can go to IRS.gov/OrderForms to place an order.\nAccess your online account (individual taxpayers \nonly). Go to IRS.gov/Account to securely access infor-\nmation about your federal tax account.\n• View the amount you owe, pay online, or set up an on-\nline payment agreement.\n• Access your tax records online.\n• Review your payment history.\n• Go to IRS.gov/SecureAccess to review the required \nidentity authentication process.\nUsing direct deposit. The fastest way to receive a tax \nrefund is to file electronically and choose direct deposit, \nwhich securely and electronically transfers your refund di-\nrectly into your financial account. Direct deposit also \navoids the possibility that your check could be lost, stolen, \nor returned undeliverable to the IRS. Eight in 10 taxpayers \nuse direct deposit to receive their refunds. The IRS issues \nmore than 90% of refunds in less than 21 days.\nGetting a transcript of your return. The quickest way \nto get a copy of your tax transcript is to go to IRS.gov/\nTranscripts. Click on either “Get Transcript Online” or “Get \nTranscript by Mail” to order a free copy of your transcript. \nIf you prefer, you can order your transcript by calling \n800-908-9946.\nReporting and resolving your tax-related identity \ntheft issues. \n• Tax-related identity theft happens when someone \nsteals your personal information to commit tax fraud. \nYour taxes can be affected if your SSN is used to file a \nfraudulent return or to claim a refund or credit.\n• The IRS doesn’t initiate contact with taxpayers by \nemail, text messages, telephone calls, or social media \nchannels to request personal or financial information. \nThis includes requests for personal identification num-\nbers (PINs), passwords, or similar information for \ncredit cards, banks, or other financial accounts.\n• Go to IRS.gov/IdentityTheft, the IRS Identity Theft \nCentral webpage, for information on identity theft and \ndata security protection for taxpayers, tax professio-\nnals, and businesses. If your SSN has been lost or \nstolen or you suspect you’re a victim of tax-related \nidentity theft, you can learn what steps you should \ntake.\n• Get an Identity Protection PIN (IP PIN). IP PINs are \nsix-digit numbers assigned to eligible taxpayers to \nhelp prevent the misuse of their SSNs on fraudulent \nfederal income tax returns. When you have an IP PIN, \nit prevents someone else from filing a tax return with \nyour SSN. To learn more, go to IRS.gov/IPPIN.\nChecking on the status of your refund. \n• Go to IRS.gov/Refunds.\n• The IRS can’t issue refunds before mid-February 2021 \nfor returns that claimed the EIC or the additional child \ntax credit (ACTC). This applies to the entire refund, \nnot just the portion associated with these credits.\n• Download the official IRS2Go app to your mobile de-\nvice to check your refund status.\n• Call the automated refund hotline at 800-829-1954.\nMaking a tax payment. The IRS uses the latest encryp-\ntion technology to ensure your electronic payments are \nsafe and secure. You can make electronic payments on-\nline, by phone, and from a mobile device using the \nIRS2Go app. Paying electronically is quick, easy, and \nfaster than mailing in a check or money order. Go to \nIRS.gov/Payments for information on how to make a pay-\nment using any of the following options.\n• IRS Direct Pay: Pay your individual tax bill or estima-\nted tax payment directly from your checking or sav-\nings account at no cost to you.\n• Debit or Credit Card: Choose an approved payment \nprocessor to pay online, by phone, or by mobile de-\nvice.\nPage 14 \nPublication 529 (December 2020)\n", "• Electronic Funds Withdrawal: Offered only when filing \nyour federal taxes using tax return preparation soft-\nware or through a tax professional.\n• Electronic Federal Tax Payment System: Best option \nfor businesses. Enrollment is required.\n• Check or Money Order: Mail your payment to the ad-\ndress listed on the notice or instructions.\n• Cash: You may be able to pay your taxes with cash at \na participating retail store.\n• Same-Day Wire: You may be able to do same-day \nwire from your financial institution. Contact your finan-\ncial institution for availability, cost, and cut-off times.\nWhat if I can’t pay now? Go to IRS.gov/Payments for \nmore information about your options.\n• Apply for an online payment agreement (IRS.gov/\nOPA) to meet your tax obligation in monthly install-\nments if you can’t pay your taxes in full today. Once \nyou complete the online process, you will receive im-\nmediate notification of whether your agreement has \nbeen approved.\n• Use the Offer in Compromise Pre-Qualifier to see if \nyou can settle your tax debt for less than the full \namount you owe. For more information on the Offer in \nCompromise program, go to IRS.gov/OIC.\nFiling an amended return. You can now file Form \n1040-X electronically with tax filing software to amend \n2019 Forms 1040 and 1040-SR. To do so, you must have \ne-filed your original 2019 return. Amended returns for all \nprior years must be mailed. See Tips for taxpayers who \nneed to file an amended tax return and go to IRS.gov/\nForm1040X for information and updates.\nChecking the status of your amended return. Go to \nIRS.gov/WMAR to track the status of Form 1040-X amen-\nded returns. Please note that it can take up to 3 weeks \nfrom the date you filed your amended return for it to show \nup in our system, and processing it can take up to 16 \nweeks.\nUnderstanding an IRS notice or letter you’ve re-\nceived. Go to IRS.gov/Notices to find additional informa-\ntion about responding to an IRS notice or letter.\nContacting your local IRS office. Keep in mind, many \nquestions can be answered on IRS.gov without visiting an \nIRS Taxpayer Assistance Center (TAC). Go to IRS.gov/\nLetUsHelp for the topics people ask about most. If you still \nneed help, IRS TACs provide tax help when a tax issue \ncan’t be handled online or by phone. All TACs now pro-\nvide service by appointment, so you’ll know in advance \nthat you can get the service you need without long wait \ntimes. Before you visit, go to IRS.gov/TACLocator to find \nthe nearest TAC and to check hours, available services, \nand appointment options. Or, on the IRS2Go app, under \nthe Stay Connected tab, choose the Contact Us option \nand click on “Local Offices.”\nThe Taxpayer Advocate Service (TAS) \nIs Here To Help You\nWhat Is TAS?\nTAS is an independent organization within the IRS that \nhelps taxpayers and protects taxpayer rights. Their job is \nto ensure that every taxpayer is treated fairly and that you \nknow and understand your rights under the Taxpayer Bill \nof Rights.\nHow Can You Learn About Your Taxpayer \nRights?\nThe Taxpayer Bill of Rights describes 10 basic rights that \nall taxpayers have when dealing with the IRS. Go to \nTaxpayerAdvocate.IRS.gov to help you understand what \nthese rights mean to you and how they apply. These are \nyour rights. Know them. Use them.\nWhat Can TAS Do For You?\nTAS can help you resolve problems that you can’t resolve \nwith the IRS. And their service is free. If you qualify for \ntheir assistance, you will be assigned to one advocate \nwho will work with you throughout the process and will do \neverything possible to resolve your issue. TAS can help \nyou if:\n• Your problem is causing financial difficulty for you, \nyour family, or your business;\n• You face (or your business is facing) an immediate \nthreat of adverse action; or\n• You’ve tried repeatedly to contact the IRS but no one \nhas responded, or the IRS hasn’t responded by the \ndate promised.\nHow Can You Reach TAS?\nTAS has offices in every state, the District of Columbia, \nand Puerto Rico. Your local advocate’s number is in your \nlocal \ndirectory \nand \nat \nTaxpayerAdvocate.IRS.gov/\nContact-Us. You can also call them at 877-777-4778.\nHow Else Does TAS Help Taxpayers?\nTAS works to resolve large-scale problems that affect \nmany taxpayers. If you know of one of these broad issues, \nplease report it to them at IRS.gov/SAMS.\nTAS for Tax Professionals\nTAS can provide a variety of information for tax professio-\nnals, including tax law updates and guidance, TAS pro-\ngrams, and ways to let TAS know about systemic prob-\nlems you’ve seen in your practice.\nLow Income Taxpayer Clinics (LITCs)\nLITCs are independent from the IRS. LITCs represent in-\ndividuals whose income is below a certain level and need \nPublication 529 (December 2020)\n Page 15\n", "to resolve tax problems with the IRS, such as audits, ap-\npeals, and tax collection disputes. In addition, clinics can \nprovide information about taxpayer rights and responsibili-\nties in different languages for individuals who speak Eng-\nlish as a second language. Services are offered for free or \na small fee for eligible taxpayers. To find a clinic near you, \nvisit TaxpayerAdvocate.IRS.gov/about/LITC or see IRS \nPub. 4134, Low Income Taxpayer Clinic List.\nPage 16 \nPublication 529 (December 2020)\n", "To help us develop a more useful index, please let us know if you have ideas for index entries.\nSee “Comments and Suggestions” in the “Introduction” for the ways you can reach us.\nIndex\n \nA\nActivities not for profit 4\nAdjustments to gross income:\nArmed forces reservists' travel \nexpenses 2\nPerforming artists 3\nState or local government officials paid on \nfee basis 3\nUnlawful discrimination claims 11\nAdministrative fees:\nIRA trustees 6\nAdoption expenses 6\nAmortizable bond premium 9\nAppraisal fees 4\nArmed forces:\nReservists, travel expenses 2\nAssistance (See Tax help)\nB\nBank accounts:\nCheck-writing fees 6\nLosses on deposits 5\nBonds:\nAmortizable premium 9\nBribes 6\nBurial expenses 6\nC\nCampaign contributions 8\nCampaign expenses 6\nCapital expenditures 6\nCasualty losses 4, 9\nCheck-writing fees 6\nClaim of right repayments 11\nClerical help, deductibility of 4\nClub dues 6\nCommissions 6\nCommuting expenses 7\nComputers:\nDepreciation 4\nConvenience fees 4\nD\nDeductions 10\nDeposits:\nLosses on 5\nDepreciation:\nComputers 4\nDisabilities, persons with:\nWork-related expenses 3\nDividends:\nFees to collect 4\nService charges on reinvestment plans 5\nDues:\nClub 6\nLobbying 7\nE\nEducator Expenses 3, 12\nEmployee business expenses:\nForm 2106 12\nPerforming artists 3\nEntertainers and \nmusicians (See Performing artists)\nEstates:\nFederal estate tax 10\nExcess deductions:\nEstates and trusts 10\nExpenses:\nAdoption 6\nCampaign 6\nCapital 6\nCommuting 7\nEducator 3\nQualified 3\nEducator Expenses 3\nFuneral and burial 6\nHealth spa 7\nHobby 4\nHome office 11\nImpairment-related 3\nInvestment 5, 7\nMeals 8\nProfessional promotion 8\nTax-exempt income 8\nF\nFederal estate tax 10\nFees:\nAppraisal 4\nCheck-writing 6\nInvestment 4, 5\nIRA trustee 6\nProfessional accreditation 8\nFines 10\nFines or penalties:\nDeductible 10\nNondeductible 7\nForm 2106:\nEmployee business expenses 12\nForm 4562:\nDepreciation and amortization 12\nFuneral expenses 6\nG\nGambling winnings and losses 10\nGovernment employees:\nState or local government officials paid on \nfee basis 3\nH\nHealth spa 7\nHobbies 4\nHome:\nSecurity system 7\nTelephone service 8\nHome office:\nExpenses 11\nPrincipal place of business 11\nI\nImpairment-related work expenses 3\nIncome in respect of decedent:\nEstate tax 10\nIndividual retirement arrangements \n(IRAs):\nTrustees' fees 6\nInsurance:\nLife insurance 7\nPersonal disability 6\nInterest income:\nFees to collect 4\nInvestments:\nAnnuity, unrecovered investment in 11\nDeposits, losses on 5\nFees and expenses 5\nSeminars 7\nItemized deductions 9\nHow to report 11\nK\nKickbacks 6\nL\nLegal expenses:\nPersonal 8\nPolitical campaigns 6\nProduction of income 5\nUnlawful discrimination claims 5\nLife insurance 7\nLobbying 7, 8\nLosses:\nCasualties and thefts 4, 9\nDeposits 5\nGambling 10\nIRA 5\nMislaid cash or property 8\nRoth IRA 5\nM\nMeal and lodging expenses:\nLunches with coworkers 8\nWorking late 8\nMissing children, photographs of 1\nMutual funds:\nIndirect deductions 5\nN\nNondeductible expenses 9\nNot-for-profit activities 4\nO\nOffice:\nRent 4\nP\nPartnerships:\nIndirect deductions 5\nPass-through entities 5\nPenalties 10\nPerforming artists 3\nWork clothes 3\nPersonal expenses 9\nPolitical contributions 8\nCampaign expenses 6\nPonzi-type investment schemes 11\nProduction of income expenses 5\nProfessional accreditation fees 8\nProfessional reputation and marketing 8\nPublications (See Tax help)\nR\nRecordkeeping requirements:\nDeductions, to verify 2\nGambling winnings and losses 10\nHome office 11\nRelief fund contributions 8\nRent:\nOffice 4\nSafe deposit box 5\nPublication 529 (December 2020)\nPage 17\n", "Repayments:\nClaim of right 11\nIncome 5\nSocial Security benefits 5\nReporting requirements:\nDepreciation 12\nForm 2106 12\nImpairment-related work expenses 3\nItemized deductions 11\nS\nSafe deposit box 5\nS corporations:\nIndirect deductions 5\nSecurity systems, home 7\nSeminars, investment-related 7\nService charges on dividend \nreinvestment plans 5\nSocial Security repayments 5\nState or local governments:\nOfficials paid on fee basis 3\nStockholders' meeting expenses 8\nT\nTaxes:\nEstate tax 10\nTax-exempt income expenses 8\nTax help 12\nTelephones:\nResidential service 8\nTheft losses 4, 9\nTravel and transportation expenses:\nAnother individual, paid by taxpayer 8\nArmed forces reservists 2\nCommuting 7\nTrustees:\nIRA administrative fees 6\nU\nUnemployment benefit fund \ncontributions 9\nUnlawful discrimination claims 11, 12\nW\nWagering winnings and losses 10\nWork:\nImpairment-related expenses 3\nWristwatches 6, 9\nPage 18\nPublication 529 (December 2020)\n" ]
p5475.pdf	1220 Publ 5475 (PDF)	https://www.irs.gov/pub/irs-pdf/p5475.pdf	[ "Publication 5475 (12-2020) Catalog Number 75189M Department of the Treasury Internal Revenue Service www.irs.gov\nFind the latest information at \nwww.irs.gov/EIP\nWhat You Need to Know About \nthe Second Economic Impact Payments\nEligibility\nGenerally, to be eligible for the second Economic Impact Payment, a person must: \n•\nhave a valid work-eligible Social Security number\n•\nmeet income requirements\n•\nnot be a dependent of someone else\nNote: Eligibility expanded for some families. Visit IRS.gov/EIP for details. \nRecovery Rebate Credit \nEligible people who didn’t receive one or both Economic Impact \nPayments or didn’t get the full amount for which they’re eligible can claim \na Recovery Rebate Credit when they file their 2020 tax return. \nAutomatic Payments\nMost people don’t need to take any steps to receive a payment. People \ncan check the status of their payments using the Get My Payment tool, \navailable in English and Spanish, only on IRS.gov. \nIncome and other limits apply.\n$600 for individuals\nEligible individuals with \nadjusted gross income up to \n$75,000 on a 2019 federal \ntax return will receive the full \n$600 payment.\n$600 per child \nPeople can also get an \nadditional $600 for each \nqualifying child under 17.\n$1,200 for married couples\nEligible married couples with adjusted \ngross income up to $150,000 on a \njoint return for 2019 will receive the full \n$1,200 payment. \n" ]
p5475sp.pdf	1220 Publ 5475 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5475sp.pdf	[ "Publication 5475 (sp) (12-2020) Catalog Number 75194F Department of the Treasury Internal Revenue Service www.irs.gov\nEncuentre información actualizada en \nwww.irs.gov/es/EIP\nLo que necesita saber acerca \ndel segundo Pago de impacto económico\nElegibilidad\nGeneralmente, para ser elegible para el segundo Pago de impacto económico, \nuna persona debe: \n•\ntener un número de Seguro Social elegible para el trabajo\n•\ncumplir con el requisito de ingresos\n•\nno ser dependiente de otra persona\nNota: La elegibilidad se extendió para algunas familias. Para más detalles, visite al IRS.gov/es/EIP. \nCrédito de recuperación \nde reembolso \nLas personas elegibles que no recibieron un Pago de impacto económico o no \nrecibieron el monto completo, pueden reclamar un Crédito de recuperación de \nreembolso cuando presenten su declaración de impuestos de 2020. \nPagos Automáticos\nLa mayoría de las personas no tienen que proveer alguna información para \nrecibir un pago. Las personas pueden verificar el estado de sus pagos \nusando la herramienta Obtener mi pago en IRS.gov. \nIngresos y otros límites aplican.\n$600 para individuos\n \nIndividuos elegibles con ingreso \nbruto ajustado de hasta $75,000 \nen una declaración de impuestos \nfederales de 2019 recibirán el \npago completo de $600.\n$600 por hijo \nLos padres también recibirán \nla cantidad adicional de $600 \npor cada hijo elegible menor \nde 17 años.\n$1,200 para parejas casadas\nParejas casadas elegibles que presentaron \nuna declaración de impuestos de 2019, \nen conjunto con ingreso bruto ajustado de \nhasta $150,000, recibirán un pago completo \nde $1,200. \n" ]
f1127.pdf	1220 Form 1127 (PDF)	https://www.irs.gov/pub/irs-pdf/f1127.pdf	[ "Form 1127\n(Rev. December 2020)\nDepartment of the Treasury \nInternal Revenue Service \nApplication for Extension of Time for Payment of \nTax Due to Undue Hardship\n ▶ Go to www.irs.gov/Form1127 for the latest information.\nOMB No. 1545-2131\nBefore you begin: Use the Determination Chart later in the instructions to see if you should file this form. \nName(s) shown on return \nIdentifying number \nNumber, street, and apt., room, or suite no. If you have a P.O. box, see instructions. \nCity, town, or post office, state, and ZIP code. If you have a foreign address, see instructions. \nPart I \nRequest for Extension \nI request an extension from \n, 20 \n, to \n, 20 \n, to pay tax of $ \n. \nCheck only one box. This request is for: \nThe tax shown or required to be shown on Form \n. \nAn amount determined as a deficiency on Form \n. \nThis request is for calendar year 20 \n, or fiscal year ending \n, 20 \n. \nPart II \nReason for Extension \nUndue hardship. Enter below a detailed explanation of the undue hardship that will result if your application is denied. (If more space \nis required, please attach a separate sheet.) To establish undue hardship, you must show that you would sustain a substantial \nfinancial loss if forced to pay a tax or deficiency on the due date. For a complete definition of “undue hardship,” see Who Should File, \nlater, in the instructions. \nPart III \nSupporting Documentation (You must check both boxes, or your application will not be accepted.)\nTo support my application, I certify that I have attached: \nA statement of my assets and liabilities at the end of last month (showing book and market values of assets and whether \nsecurities are listed or unlisted), and \nAn itemized list of my income and expenses for each of the 3 months prior to the due date of the tax. \nSignature and Verification \nUnder penalties of perjury, I declare that I have examined this application, including any accompanying schedules and statements, and to the best of my \nknowledge and belief, it is true, correct, and complete; and, if prepared by someone other than the taxpayer, that I am authorized to prepare this form. \nSignature of taxpayer ▶\nDate ▶\nSignature of spouse ▶\nDate ▶\nSignature of preparer \nother than taxpayer ▶\nDate ▶\nFOR IRS USE ONLY (Do not detach) \nThis application is \nApproved \nDenied \nReturned: \nReason(s): \nSignature of authorized official \nDate \nFor Privacy Act and Paperwork Reduction Act Notice, see instructions. \nCat. No. 17238O \nForm 1127 (Rev. 12-2020) \n", "[ This page left blank intentionally ] \n", "Form 1127 (Rev. 12-2020) \nPage 3 \nSection references are to the Internal Revenue Code. \nGeneral Instructions \nWhat’s New\nWhere to file. If the tax due is a gift tax reportable on Form 709, \nUnited States Gift (and Generation-Skipping Transfer) Tax Return, \nsend your Form 1127 to the updated address under Where To File, \nlater.\nPurpose of Form \nUse Form 1127 to request an extension of time under section \n6161 for payment of the following amounts. \n• The tax shown or required to be shown on a return. \n• An amount determined as a deficiency (an amount you owe \nafter an examination of your return). \nDetermination Chart \nUse this chart to determine if Form 1127 is the correct form for you \nto file. \nIF you . . . \nTHEN . . . \nAre requesting to postpone \npayment of the full amount of \ntax shown or required to be shown \non your return or an amount \ndetermined as a deficiency \nFile Form 1127. See When To File, \nlater, for due dates.\nAre seeking an extension of \ntime to file your income tax \nreturn \nFile Form 4868, Application for \nAutomatic Extension of Time To \nFile U.S. Individual Income Tax \nReturn, or Form 2350, Application \nfor Extension of Time To File U.S. \nIncome Tax Return. Do not file \nForm 1127. \nAre seeking an extension of \ntime to pay estate (and \ngeneration-skipping transfer) \ntaxes\nFile Form 4768, Application for \nExtension of Time To File a \nReturn and/or Pay U.S. Estate \n(and Generation-Skipping \nTransfer) Taxes. Do not file \nForm 1127. \nAre requesting a monthly \ninstallment payment plan \nSee Form 9465, Installment \nAgreement Request, or go to \nOnline Payment Agreement \nApplication at www.irs.gov/OPA. \nDo not file Form 1127.\nOwe any tax and are not \nrequesting, or do not qualify \nfor, either a monthly installment \npayment plan or an extension of \ntime to pay the full amount \nCall, write, or visit your local IRS \noffice to discuss your situation. \nFor more information, see Pub. \n594, The IRS Collection Process. \nDo not file Form 1127. \nWho Should File \nYou can file Form 1127 if you will owe any of the following, and \npaying the tax at the time it is due will cause an undue hardship. \n• Income taxes. \n• Self-employment income taxes. \n• Withheld taxes on nonresident aliens and foreign corporations. \n• Taxes on private foundations and certain other tax-exempt \norganizations. \n• Taxes on qualified investment entities. \n• Taxes on greenmail. \n• Taxes on structured settlement factoring transactions. \n• Gift taxes. \nForm 1127 can also be filed if you receive a notice and demand for \npayment (or tax bill) for any of the taxes shown below and paying \nthem at the time they are due will cause an undue hardship. \n• Normal taxes and surtaxes. \n• Taxes on private foundations and certain other tax-exempt \norganizations. \n• Taxes on qualified investments. \n• Gift taxes. \nUndue hardship. The term “undue hardship” means more than an \ninconvenience. You must show you will have a substantial financial \nloss (such as selling property at a sacrifice price) if you pay your tax \non the date it is due. \nWhen To File \nForm 1127, and its supporting documentation, should be filed as \nsoon as you are aware of a tax liability or a tax deficiency you \ncannot pay without causing undue hardship. \nIf you are requesting an extension of time to pay the full amount \nof tax shown or required to be shown on an upcoming return, Form \n1127 must be received on or before the due date of that return, not \nincluding extensions. \nIf you are requesting an extension of time to pay an amount \ndetermined as a deficiency, Form 1127 must be received on or \nbefore the due date for payment indicated in the tax bill. \nWhere To File \nFile Form 1127 with the Internal Revenue Service (Attn: Advisory \nGroup Manager) for the area where you maintain your legal \nresidence or principal place of business. See Pub. 4235, Collection \nAdvisory Group Numbers and Addresses, to find the address for \nyour local advisory group. \nHowever, if the tax due is a gift tax reportable on Form 709, send \nForm 1127 to: \nDepartment of the Treasury \nInternal Revenue Service \nStop 824G \n7940 Kentucky Drive \nFlorence, KY 41042-2915\nExtension Period \nAn extension of more than 6 months generally will not be granted \nto pay the tax shown on a return. However, except for taxes due \nunder sections 4981, 4982, and 5881, an extension for more than \n6 months may be granted if you are out of the country. \nAn extension to pay an amount determined as a deficiency is \ngenerally limited to 18 months from the date payment is due. \nHowever, in exceptional circumstances, an additional 12 months \nmay be granted. \nNote: An extension to pay a deficiency will not be granted if the \ndeficiency is due to negligence, intentional disregard of rules and \nregulations, or fraud with intent to evade tax. \nPayment Due Date \nYou must pay the tax before the extension runs out. Do not wait \nto receive a bill from the IRS. \n", "Form 1127 (Rev. 12-2020) \nPage 4 \nInterest. You will owe interest on any tax not paid by the due date \nof the return, or the due date of any amount determined to be a \ndeficiency, regardless of whether an extension of time to pay the \ntax has been obtained. The interest runs until you pay the tax. \nPenalties. Penalties may be imposed if you fail to pay the tax \nwithin the extension period granted. \nSpecific Instructions \nName, Address, and Identification Number \nIndividuals. Enter your name, address, and social security number \n(SSN) or individual taxpayer identification number (ITIN). If this \napplication is for the tax shown on a joint return or a joint tax \nliability for an amount determined as a deficiency, include both \nspouses’ names in the order in which they appear or will appear on \nyour return, and enter the SSN or ITIN of the spouse whose name \nappears first. \nCorporations. Enter your company’s name, address, and employer \nidentification number. \nP.O. box. Enter your box number only if your post office does not \ndeliver to your street address. \nForeign address. Enter the information in the following order: city, \nprovince or state, and country. Follow the country’s practice for \nentering the postal code. Do not abbreviate the country name. \nPart I \nRequest for extension. Enter the due date of your return (not \nincluding extensions) or the due date for paying the amount \ndetermined as a deficiency. Enter the date you propose to pay the \ntax and the amount of tax you owe. The date you propose to pay \nthe tax can be up to: \n• 6 months from the due date of your return (not including \nextensions), if your request is for payment of the tax shown on your \nreturn (the date you propose can be more than 6 months if you are \nout of the country); or \n• 18 months from the date payment is due, if your request is for \npayment of an amount determined as a deficiency (an additional 12 \nmonths can be requested for a deficiency in exceptional \ncircumstances). \nCheck the applicable box and enter the form number to which the \ntax you owe relates. Enter the tax year, if the tax you owe is figured \non a calendar year; if the tax you owe is figured on a fiscal year, \nenter the ending month, day, and year. \nPart II \nReason for extension. In order for your application to be \nconsidered, you must provide a detailed explanation of the undue \nhardship that will result if you pay the tax on or before the due date. \nAn extension will not be granted if you provide only a general \nstatement of hardship. \nPart III \nSupporting documentation. You must attach: \n• A statement(s) of your assets and liabilities, and \n• An itemized list of your income and expenses for each of the 3 \nmonths prior to the due date of the tax. \nNote: Once your request has been reviewed, additional conditions \nmay have to be met. \nSignature and Verification \nThis form must be signed and dated. \nIndividuals. If this application is for the tax shown on a joint return \nor a joint tax liability for an amount determined as a deficiency, \nboth you and your spouse must sign and date this form. If your \nspouse cannot sign, see Pub. 501, Exemptions, Standard \nDeduction, and Filing Information. \nPrivacy Act and Paperwork Reduction Act Notice. We ask for \nthe information on this form to carry out the Internal Revenue laws \nof the United States. We need this information to ensure \ncompliance with these laws and to properly grant extensions of \ntime to pay tax. Applying for an extension of time for the payment \nof tax is voluntary. However, providing the requested information is \nmandatory if you apply for the extension. Our legal right to ask for \nthe information requested on this form is based in sections 6001, \n6011, 6109, and 6161 and their regulations. If you fail to provide all \nor part of the information requested, your application may be \ndenied. If you provide false or fraudulent information, you may be \nsubject to penalties. \nYou are not required to provide the information requested on a \nform that is subject to the Paperwork Reduction Act unless the \nform displays a valid OMB control number. Books or records \nrelating to a form or its instructions must be retained as long as \ntheir contents may become material in the administration of any \nInternal Revenue law. Generally, tax returns and return information \nare confidential, as required by section 6103. However, section \n6103 allows or requires the Internal Revenue Service to disclose \nthe information to others as described in the Code. For example, \nwe may disclose this information to the Department of Justice for \nenforcement of civil or criminal tax laws; to cities, states, the \nDistrict of Columbia, and U.S. commonwealths or possessions to \nadminister their tax laws; to other countries under a tax treaty; to \nfederal and state agencies to enforce non-tax criminal laws; or to \nfederal law enforcement and intelligence agencies to combat \nterrorism. \nEstimates of taxpayer burden. The time needed to complete and \nfile this form will vary depending on individual circumstances. The \nestimated burden for individual taxpayers filing this form is \napproved under OMB control number 1545-0074 and is included in \nthe estimates shown in the instructions for their individual income \ntax return. The estimated burden for all other taxpayers who file this \nform is shown below. \nRecordkeeping .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. 3 hr., 6 min. \nLearning about the \nlaw or the form .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. 55 min. \nPreparing and sending \nthe form to the IRS .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. 3 hr., 25 min. \nIf you have comments concerning the accuracy of these time \nestimates or suggestions for making this form simpler, we would \nbe happy to hear from you. See the instructions for the tax return \nfor which this form is filed. \n" ]
i965b.pdf	0121 Inst 965-B (PDF)	https://www.irs.gov/pub/irs-pdf/i965b.pdf	[ "Instructions for Form 965-B\n(Rev. January 2021)\nCorporate and Real Estate Investment Trust (REIT) Report of Net 965 Tax Liability \nand Electing REIT Report of 965 Amounts\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nFor the latest information about developments related to Form \n965-B and its instructions, such as legislation enacted after they \nwere published, go to IRS.gov/Form965B.\nWhat’s New\nIn Parts I, II, and III of the form, line 4 is now designated for use \nfor 2020 reporting.\nChanges to the carryback of net operating losses. The \nCoronavirus Aid, Relief, and Economic Security Act (CARES \nAct) added section 172(b)(1)(D)(i), which provides for a \ncarryback of any net operating loss (NOL) arising in a taxable \nyear beginning after December 31, 2017, and before January 1, \n2021, to each of the five taxable years preceding the taxable \nyear in which the loss arises, including those years in which a \ntaxpayer had a section 965(a) inclusion (section 965 years). A \ntaxpayer applying for a tentative refund resulting from the \ncarryback of an NOL to a section 965 year must include with the \nForm 1139 an amended Form 965-B to record the amount of the \nchange in the section 965 net tax liability, if any, caused by the \nNOL carryback, and a statement of explanation to explain the \nchange in the section 965 net tax liability. See Rev. Proc. \n2020-24, 2020-18 I.R.B. 750, and Frequently asked questions \nabout carrybacks of NOLs for taxpayers who have had Section \n965 inclusions for additional information regarding the \nconsequences of carrying back an NOL to a section 965 year, \nincluding limitations on refunds for taxpayers that carry back \nNOLs to section 965 years.\nReminders\nThe IRS has developed Form 965-C, Transfer Agreement Under \nSection 965(h)(3). The instructions for this form contain \ninformation that may be useful to filers of Form 965-B. As such, \nreferences to the instructions for Form 965-C have been added \nto Part I of these instructions for Form 965-B.\nBackground\nOn December 22, 2017, section 965 of the Code was amended. \nAs a result of the amendment, certain taxpayers are required to \ninclude in income an amount (a section 965(a) inclusion amount) \nbased on the accumulated post-1986 deferred foreign income of \ncertain foreign corporations (specified foreign corporations) that \nare deferred foreign income corporations (DFICs) that they own \neither directly or indirectly through other entities. Other taxpayers \nmay have inclusions in income under section 951(a) by reason \nof section 965 due to ownership of DFICs through domestic \npass-through entities that are U.S. shareholders of the DFICs. \nWhen referring to both amounts in the preceding two sentences, \nthese instructions use the term “section 965(a) inclusion.” \nSection 965 also allows for a deduction (section 965(c) \ndeduction). Section 965(a) inclusions and corresponding section \n965(c) deductions are taken into account based on the last tax \nyear of the DFIC that begins before January 1, 2018.\nCertain taxpayers may make certain elections with respect to \nsection 965. Relevant to this form, these elections include (i) an \nelection to pay a net 965 tax liability over 8 years, and (ii) an \nelection by real estate investment trusts (REITs) to take into \naccount a section 965(a) inclusion and section 965(c) deduction \nover an 8-year time period beginning in the year such amounts \nwould otherwise have been taken into account. An electing REIT \nmust complete Part III of Form 965-B.\nGeneral Instructions\nPurpose of Form\nThis form should be used by corporate taxpayers and REITs. \nThis form is used to report a taxpayer’s net 965 tax liability for \neach tax year in which a taxpayer must pay or include section \n965 amounts. In addition, this form is used to report the \ndetermination of a taxpayer’s net 965 tax liability, whether or not \nit is to be paid in installments; the payments of a net 965 tax \nliability; and adjustments of any net 965 tax liabilities \noutstanding, including any net 965 tax liability of the taxpayer \nthat has been assumed by another taxpayer or any net 965 tax \nliability that the taxpayer has assumed. For an electing REIT, this \nform also is used to report the section 965 amounts it elects to \ntake into account over an 8-year time period; the portion of the \namounts taken into account for each reporting year; and the \namount remaining to be taken into account after a reporting year. \nIn summary, this form is intended to be a cumulative report of a \ntaxpayer’s net 965 tax liabilities through payment in full, and for \nan electing REIT, a report of section 965 amounts taken into \naccount over time until such amounts are fully taken into \naccount. This form must be completed by a taxpayer for every \ntax year for which the taxpayer has any net 965 tax liability \noutstanding and not fully paid at any point during the tax year. \nFurthermore, this form must be completed by an electing REIT \nfor every tax year for which the REIT has any section 965 \namounts taken into account in accordance with section 965(m) \nor not fully taken into account at any point during the tax year.\nDefinitions\nDeferred foreign income corporation (DFIC). A DFIC is, with \nrespect to any U.S. shareholder, any specified foreign \ncorporation (as defined under section 965(e)) of a U.S. \nshareholder that has accumulated post-1986 deferred foreign \nincome (as defined under section 965(d)(2)) as of November 2, \n2017, or December 31, 2017, that is greater than zero.\nU.S. shareholder. For tax years of foreign corporations \nbeginning before January 1, 2018, a U.S. shareholder is a U.S. \nperson who owns (directly, indirectly, or constructively) 10% or \nmore of the total combined voting power of all classes of stock of \na foreign corporation. A U.S. person for this purpose is defined \nin section 957(c) of the Code.\nNet income tax liability. The taxpayer’s regular income tax \nliability reduced by the credits allowed under subparts A, B, and \nD of part IV of subchapter A (generally non-refundable credits; \nspecifically, those credits allowed under sections 21 through \n30D and sections 38 through 45T).\nNet 965 tax liability. The excess of the taxpayer’s net income \ntax liability computed with all section 965 amounts included \n(“with calculation”) over the taxpayer’s net income tax liability \nDec 15, 2020\nCat. No. 71281P\n", "without regard to section 965 (“without calculation”). See \nRegulations section 1.965-7(g)(10) for rules for computing the \nnet 965 tax liability.\nReporting year. The tax year of the return with which this form \nis being filed.\nWho Must File\nAny corporate taxpayer who has a net 965 tax liability for any tax \nyear or has any net 965 tax liability remaining unpaid at any time \nduring a tax year, or an electing REIT with any section 965 \namount taken into account in accordance with section 965(m) or \nnot taken into account at any time during a tax year, must file this \nform.\nWhen and Where To File\nFile Form 965-B with the income tax return of the taxpayer for \nthe reporting year by the due date (taking into account \nextensions, if any) of the return.\nElectronic Filing of Form 965-B\nIf you file your income tax return electronically, Form 965-B is \nfiled with the electronic income tax return. See the instructions \nfor your income tax return for general information about \nelectronic filing.\nSpecific Instructions\nAmended Report\nCheck the amended report box at the top of page 1 of the form if \nForm 965-B is filed with an amended return that is filed to \nchange any reporting related to section 965, regardless of \nwhether a Form 965-B has previously been filed. The amended \nreturn box must also be checked for any amended Form 965-B \nfiled with a Form 1139 applying for a tentative refund resulting \nfrom the carryback of an NOL to a section 965 year pursuant to \nsection 172(b)(1)(D)(i).\nPart I – Report of Net 965 Tax Liability \nand Election To Pay in Installments\nLines 1 through 8. Report in Part I net 965 tax liability amounts \nas follows.\nOn lines 1, 2 and 3, you must continue to report 2017, 2018, \nand/or 2019 amounts for all columns, including the original \ncomputation of net 965 tax liability reported in columns (b) \nthrough (g) on a prior-year Form 965-B. Report in column (h) any \ncurrent tax year net 965 tax liability transferred out (that is, for \nwhich you filed a valid transfer agreement as the transferor) or \nany current tax year subsequent adjustments. Also complete \ncolumn (i) if applicable.\nFor 2020 tax years, use line 4 to report section 965(a) \ninclusions derived solely through interests in pass-through \nentities that are U.S. shareholders of DFICs.\nUse lines 5 through 8 to report other amounts of net 965 tax \nliability of the taxpayer, such as:\n• Installment liability transfers in. The taxpayer may, in \ncertain circumstances, and by agreement with the Secretary, \nassume as transferee the installment payment liability for the \ntransferor's remaining net 965 tax liability and pay it in the same \nmanner as if the taxpayer were the transferor. (See instructions \nfor Form 965-C for more details.) If this occurs, the transferee \nshould complete one of lines 5 through 8 in Part I as follows:\n• In column (a), enter the tax year of the net 965 tax liability for \nwhich the installment payment liability is being assumed. For \nexample, if a net 965 tax liability incurred in tax year 2017 (with \nrespect to which an installment payment election was made) \nwas transferred to a taxpayer (transferee) in 2022, in 2022 the \ntaxpayer (transferee) reports “2017” in column (a).\n• Skip columns (b) through (g).\n• In column (h), report, as a positive number, the remaining \ninstallment payment liability assumed by the taxpayer as \ntransferee. Then report the tax identification number of the \ntransferor in column (i). Payments of such liability would then be \nreported on the corresponding line of Part II in the same manner \nas if the taxpayer were the transferor.\nFor example, assume Transferor had an original net 965 tax \nliability of $100 in year 1, when an installment payment election \nwas made. In years 1 through 5, Transferor reports payments of \nfive 8% installments. Then, in year 6, the liability to pay the \nremaining installments (15%, 20%, and 25%) totaling $60 is \ntransferred to Taxpayer as transferee. Taxpayer would report on \na line in Part I the tax year of the net 965 tax liability for which the \ninstallment payment liability is being assumed in column (a); the \n$60 amount of the transfer as a positive number in column (h); \nand the tax identification number of Transferor in column (i). In \naddition, on the corresponding line in Part II, Taxpayer would \nreport the $15 installment payment made in column (g), Paid for \nYear 6 (the installment year as if Taxpayer were paying as \nTransferor). In the next reporting year, Taxpayer would report all \nthe same information in Part II, plus the payment of $20 (20% of \nthe original $100 liability) in column (h), Paid for Year 7. In the \nfollowing reporting year, Taxpayer would report all the same \ninformation as in year 7, plus the final payment of $25 (25% of \nthe original $100 liability) in column (i), Paid for Year 8.\nNote. If lines 5 through 8 do not provide enough lines to report \nall the taxpayer’s transactions described above, an additional \nForm 965-B should be used.\nNote. Even if a net 965 tax liability was reported on a taxpayer’s \nincome tax return and fully paid, because no elections were \nmade, the taxpayer must complete the appropriate line in Part I \nand report the related payment in Part II, column (b).\nNote. If an installment election under section 965(h) was made, \nthe taxpayer must complete the appropriate line in Part I as well \nas the corresponding line in Part II to report the status of the net \n965 tax liability and any related adjustments for the reporting \nyear.\nColumn (b). Report the taxpayer’s net income tax liability for \nthe tax year reported in column (a), with all section 965 amounts \nincluded (“with calculation”).\nColumn (c). Report the taxpayer’s net income tax liability for \nthe tax year reported in column (a), without regard to section 965 \n(“without calculation”).\nColumn (d). Report the excess of the taxpayer’s “with \ncalculation” reported in column (b) over the “without calculation” \nreported in column (c). This is the taxpayer’s net 965 tax liability \nfor the tax year reported in column (a).\nFor tax year 2020, corporations are required to enter the \namount from Form 965-B, Part I, column (d), line 4, on Form \n1120, Schedule J, Part III, line 22, or on the corresponding line of \nother corporate income tax returns.\nColumn (e). If the taxpayer made an election to pay a net 965 \ntax liability in installments over 8 years as provided for in section \n965(h) and in the manner described in Regulations section \n1.965-7(b)(2), enter a check mark in the “Yes” column. If “Yes,” \nskip column (f) and enter the amount from column (d) in column \n(g). Otherwise, enter a check mark in the “No” column. If “No,” \nenter the amount from column (d) in column (f) and skip column \n(g).\n-2-\nInstructions for Form 965-B (Rev. 01-2021)\n", "The actual payment of the first installment is due no later \nthan the due date of the return for the tax year without \nextension, even if the election is made on a return filed \nby the extended due date.\nA REIT electing to account for its section 965 amounts over 8 \nyears may not make an installment election for any net 965 tax \nliability for a tax year in which a portion of such section 965 \namounts is taken into account. If an election is made to account \nfor a REIT's section 965 amounts over 8 years, the portion of the \nnet 965 tax liability attributable to the section 965 amounts \nincluded in each year must be paid in full for that year.\nColumn (h). Report the following in column (h):\n• Report, as a negative number, any net 965 tax liability for the \nyear reported in column (a) that has been transferred out to a \ntransferee by agreement with the Secretary, under which the \ntransferee becomes liable for the remaining installments due on \nthe liability in the same manner as if such transferee were the \ntaxpayer. (See instructions for Form 965-C for more details.) In \naddition, provide the tax identification number of the transferee \nin column (i). For example, if the taxpayer (transferor) incurred a \nnet 965 tax liability in tax year 2017, for which an installment \npayment election was made, then properly transferred the \nliability net of payments previously made to a transferee in 2022, \nthe taxpayer (transferor) would report, on line 1, column (h), as a \nnegative number, the amount of the net liability transferred out. \nThe making and reporting of payments on such liability should \ngenerally cease. However, reporting with respect to the net 965 \ntax liability is still required for the reporting year if any net 965 tax \nliability of the taxpayer remains unpaid at any time during the \nreporting year.\n• Report any transfer in of a net 965 tax liability from a \ntransferor by a transferee (see instructions for lines 1 through 8, \nearlier).\n• Report subsequent adjustments to the net 965 tax liability for \nthe tax year reported in column (a) for which no amended return \nwas required to be filed, such as an audit adjustment. A liability \nincrease should be reported as a positive number and a \ndecrease as a negative number.\nNote. An adjustment of a net 965 tax liability elected to be paid \nin installments generally is prorated to all installments.\nFor example, for tax year 2017, a taxpayer (TP) reported a \n$100 net 965 tax liability for which an installment election was \nmade. For each of years 1 through 5, TP pays and reports an $8 \ninstallment. Also, in year 5, an audit adjustment increases the \n2017 net 965 tax liability to $150, a $50 positive adjustment. No \namended return was required and there was no negligence, \nintentional disregard, or fraud on the part of TP. This adjustment \nwould be prorated to all the installments. TP would report the \n$50 adjustment in Part I, line 1, column (h) as a positive number, \nso the reported adjusted liability would be $150. In addition, TP \nwould pay and report (in addition to the original $8 installment \nreported for year 5) $20 on Part II, line 1, column (f), \nrepresenting 8% of the adjustment prorated to each of years 1 \nthrough 5, for which the installment due date had already \narrived. For year 6, TP would pay and report $22.50 (15% of the \nadjusted liability); for year 7, $30 (20% of the adjusted liability); \nand for year 8, $37.50 (25% of the adjusted liability).\nIn a case in which a net 965 tax liability for a tax year is both \nadjusted and transferred, report the net adjustment/transfer \nnumber in column (h), a transferee tax identification number in \ncolumn (i), and provide a statement attached to this form which \nincludes details of the amounts netted in column (h).\nCAUTION\n!\nPart II – Record of Amount of Net 965 \nTax Liability Paid by the Taxpayer\nPart II is intended to be a cumulative record of the actual \npayments the taxpayer has made with respect to the net 965 tax \nliabilities reported in Part I.\nLine 1. This line records the actual payments with respect to the \nnet 965 tax liability reported on line 1 of Part I for the tax year \n2017.\nThe general installment payment schedule for a net 965 tax \nliability subject to an election to pay in installments is:\n1.\n8% of the net 965 tax liability payable in year 1, the year \nof the section 965(a) inclusion,\n2.\n8% of the net 965 tax liability payable in year 2,\n3.\n8% of the net 965 tax liability payable in year 3,\n4.\n8% of the net 965 tax liability payable in year 4,\n5.\n8% of the net 965 tax liability payable in year 5,\n6.\n15% of the net 965 tax liability payable in year 6,\n7.\n20% of the net 965 tax liability payable in year 7, and\n8.\n25% of the net 965 tax liability payable in year 8.\nIf, for any reason, the actual payment differs from the \nschedule, report the actual payment made.\nExample. If the reporting year is 2020 and the taxpayer is \nreporting a 2017 net 965 tax liability for which an installment \npayment election was made, because the 2020 reporting year is \n“Year 4” with respect to a 2017 net 965 tax liability being paid in \ninstallments, installment payments reported in Part II on line 1, \nthe line for 2017, should generally be:\n• In column (b), Paid for Year 1, report 8% of the 2017 net 965 \ntax liability;\n• In column (c), Paid for Year 2, report 8% of the 2017 net 965 \ntax liability;\n• In column (d), Paid for Year 3, report 8% of the 2017 net 965 \ntax liability; and\n• In column (e), Paid for Year 4, report 8% of the 2017 net 965 \ntax liability.\nColumn (a). For lines 5 through 8, report the tax year of the \nsection 965(a) inclusion or the net 965 tax liability for which an \ninstallment payment liability is being assumed, as reported on \nthe corresponding line of Part I, column (a).\nColumns (b) through (i). These columns are used to record \nthe taxpayer’s cumulative payments, made each reporting year, \nfor the net 965 tax liability reported on the corresponding line in \nPart I.\nIf no installment election is made, the net 965 tax liability \nreported in Part I, column (f), should be paid and reported on the \ncorresponding line of Part II, column (b), Paid for Year 1, and the \nremaining payment columns (c) through (i) left blank.\nIf an installment election is made, and no transfers, \nacceleration events, or adjustments occur during the 8-year \ninstallment period, then:\n• 8% of the net 965 tax liability should be paid and reported in \ncolumn (b), Paid for Year 1 (the year of the installment payment \nelection).\n• In the next reporting year, the relevant information from the \nprior reporting year should be carried forward, plus 8% of the net \n965 tax liability should be paid and reported in column (c), Paid \nfor Year 2.\n• In future reporting years, the payments and payment reporting \nshould continue similarly in accordance with the general \ninstallment payment schedule described above.\nIf the taxpayer transfers out a net 965 tax liability, then the \nmaking and reporting of installment payments should generally \nInstructions for Form 965-B (Rev. 01-2021)\n-3-\n", "cease for the transferred net 965 tax liability in the year of \ntransfer. However, reporting with respect to the net 965 tax \nliability is still required for the reporting year if any net 965 tax \nliability of the taxpayer remains unpaid at any time during the \nreporting year.\nIf an acceleration event occurs, then the unpaid portion of all \nremaining installments is generally due on the date of the \nacceleration event and should be paid and reported in the \ncolumn for the year in which the acceleration event occurs. \nHowever, reporting with respect to the net 965 tax liability is still \nrequired for the reporting year if any net 965 tax liability of the \ntaxpayer remains unpaid at any time during the reporting year.\nIf an adjustment occurs to a net 965 tax liability for which an \ninstallment election has been made, including on an amended \nreturn, the adjustment generally should be prorated over all the \ninstallment payments. For the part of the adjustment prorated to \ninstallments whose payment date has already arrived, adjust the \npayment for the reporting year in which the adjustment is made \nand report accordingly. For the part of the adjustment prorated to \ninstallments for which the payment date has not yet arrived, pay \nand report in accordance with the installment schedule.\nPayments should include both actual installment payments \nmade and excess payments of other income tax liabilities \napplied to the taxpayer’s net 965 tax liability.\nColumn (j). Report the net 965 tax liability remaining unpaid \nafter the payment for the reporting year. This amount should \nequal the amount reported on the corresponding line in Part I, \ncolumn (d), plus or minus any amount reported on the \ncorresponding line in Part I, column (h), less any payments \nreported in Part II, columns (b) through (i).\nColumn (k). For each line, report only the payment made (if \nany) for the reporting year.\nFor tax year 2020, corporations are required to enter the \namount from Form 965-B, Part II, column (k), line 4, on Form \n1120, Schedule J, Part II, line 12, or on the corresponding line of \nother corporate income tax returns.\nPart III – Electing REIT Report of \nSection 965 Amounts Accounted for \nOver Time\nColumn (b). Report the amount of the section 965(a) inclusion \nand the section 965(c) deduction to which the election relates.\nColumns (c) through (j). Report the portion of the section \n965(a) inclusion and 965(c) deduction taken into account for the \nyear to which the election relates and subsequent years in the \nelected 8-year time period. The reporting should generally follow \nthe schedule immediately below.\nThe general schedule for taking into account the section \n965(a) inclusion and section 965(c) deduction is:\n• 8% of the amounts are taken into account in year 1 (year to \nwhich the election relates),\n• 8% of the amounts are taken into account in year 2,\n• 8% of the amounts are taken into account in year 3,\n• 8% of the amounts are taken into account in year 4,\n• 8% of the amounts are taken into account in year 5,\n• 15% of the amounts are taken into account in year 6,\n• 20% of the amounts are taken into account in year 7, and\n• 25% of the amounts are taken into account in year 8.\nFor example, if the reporting year is 2020, and a REIT is \nreporting a 2017 section 965(a) inclusion and section 965(c) \ndeduction for which an election was made to report the section \n965 amounts over time, because the 2020 reporting year is \n“Year 4” with respect to the 2017 section 965 amounts, the \nportions of the amounts taken into account should generally be \nreported as:\n• Column (c), Portion Accounted for in Year 1, report 8% of the \n2017 section 965(a) inclusion and 8% of the section 965(c) \ndeduction,\n• Column (d), Portion Accounted for in Year 2, report 8% of the \n2017 section 965(a) inclusion and 8% of the section 965(c) \ndeduction,\n• In column (e), Portion Accounted for in Year 3, report 8% of \nthe 2017 section 965(a) inclusion and 8% of the section 965(c) \ndeduction, and\n• In column (f), Portion Accounted for in Year 4, report 8% of \nthe 2017 section 965(a) inclusion and 8% of the section 965(c) \ndeduction.\nIn future reporting years, report the amounts taken into \naccount in prior years in the appropriate columns plus the \namounts taken into account in the reporting year in the \nappropriate column in accordance with the above general \nschedule for taking into account the section 965 amounts, \nassuming no acceleration events occur.\nIf an acceleration event occurs, the section 965(a) inclusion \nand 965(c) deduction remaining to be taken into account must \nbe taken into account as of the day before the acceleration event \noccurs and reported for the year in which the acceleration event \noccurs. An acceleration event is a liquidation, sale, exchange, or \nother disposition of substantially all of the assets of the REIT \n(including in a bankruptcy proceeding or similar case), or a \ncessation of business by the REIT.\nColumn (k). Report the amount of the section 965(a) inclusion \nand section 965(c) deduction remaining to be taken into account \nat the end of the reporting year. This should equal the amount \nreported in column (b) less any amounts reported in columns \n(c)-(j).\nColumn (l). For each line, report only the portion of the section \n965(a) inclusion and section 965(c) deduction taken into account \nfor the reporting year.\nPaperwork Reduction Act Notice\nWe ask for the information on this form to carry out the Internal \nRevenue laws of the United States. You are required to give us \nthe information. We need it to ensure that you are complying \nwith these laws and to allow us to figure and collect the right \namount of tax.\nYou are not required to provide the information requested on \na form that is subject to the Paperwork Reduction Act unless the \nform displays a valid OMB control number. Books or records \nrelating to a form or its instructions must be retained as long as \ntheir contents may become material in the administration of any \nInternal Revenue law. Generally, tax returns and return \ninformation are confidential, as required by section 6103.\nThe time needed to complete and file this form will vary \ndepending on individual circumstances. The estimated burden \nfor business taxpayers filing this form is approved under OMB \ncontrol number 1545-0123 and is included in the estimates \nshown in the instructions for their business income tax return.\n-4-\nInstructions for Form 965-B (Rev. 01-2021)\n" ]
i965a.pdf	0121 Inst 965-A (PDF)	https://www.irs.gov/pub/irs-pdf/i965a.pdf	[ "Instructions for Form 965-A\n(Rev. January 2021)\nIndividual Report of Net 965 Tax Liability\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nFor the latest information about developments related to Form \n965-A and its instructions, such as legislation enacted after they \nwere published, go to IRS.gov/Form965A.\nWhat’s New\nIn Parts I, II, and III of the form, line 4 is now designated for use \nfor 2020 reporting.\nChanges to the carryback of net operating losses. The \nCoronavirus Aid, Relief, and Economic Security Act (CARES \nAct) added section 172(b)(1)(D)(i), which provides for a \ncarryback of any net operating loss (NOL) arising in a taxable \nyear beginning after December 31, 2017, and before January 1, \n2021, to each of the five taxable years preceding the taxable \nyear in which the loss arises, including those years in which a \ntaxpayer had a section 965(a) inclusion (section 965 years). A \ntaxpayer applying for a tentative refund resulting from the \ncarryback of an NOL to a section 965 year must include with the \nForm 1045 an amended Form 965-A to record the amount of the \nchange in the section 965 net tax liability, if any, caused by the \nNOL carryback, and a statement of explanation to explain the \nchange in the section 965 net tax liability. See Rev. Proc. \n2020-24, 2020-18 I.R.B. 750, and Frequently asked questions \nabout carrybacks of NOLs for taxpayers who have had Section \n965 inclusions for additional information regarding the \nconsequences of carrying back an NOL to a section 965 year, \nincluding limitations on refunds for taxpayers that carry back \nNOLs to section 965 years.\nReminders\nThe IRS has developed the following forms:\n• Form 965-C, Transfer Agreement Under Section 965(h)(3).\n• Form 965-D, Transfer Agreement Under Section 965(i)(2).\n• Form 965-E, Consent Agreement Under Section 965(i)(4)(D).\nThe instructions for these forms contain information that may \nbe useful to filers of Form 965-A. As such, references to these \ninstructions have been added throughout the instructions for \nForm 965-A.\nBackground\nOn December 22, 2017, section 965 of the Code was amended. \nAs a result of the amendment, certain taxpayers are required to \ninclude in income an amount (a section 965(a) inclusion amount) \nbased on the accumulated post-1986 deferred foreign income of \ncertain foreign corporations (specified foreign corporations) that \nare deferred foreign income corporations (DFICs) that they own \neither directly or indirectly through other entities. Other taxpayers \nmay have inclusions in income under section 951(a) by reason \nof section 965 due to ownership of DFICs through domestic \npass-through entities that are U.S. shareholders of the DFICs. \nWhen referring to both amounts in the preceding two sentences, \nthese instructions use the term “section 965(a) inclusion.” \nSection 965 also allows for a deduction (section 965(c) \ndeduction). Section 965(a) inclusions and corresponding section \n965(c) deductions are taken into account based on the last tax \nyear of the DFIC that begins before January 1, 2018.\nCertain taxpayers may make certain elections with respect to \nsection 965. Relevant to this form, these elections include: (i) an \nelection to pay a net 965 tax liability over 8 years, and (ii) an \nelection by S corporation shareholders to defer payment of a net \n965 tax liability with respect to an S corporation until a triggering \nevent. In the case of the deferral election by S corporation \nshareholders, the deferred amounts are subject to annual \nreporting requirements, and when a triggering event occurs, the \nS corporation shareholder may then (subject to certain \nlimitations) elect to pay the amount of the net 965 tax liability that \nis no longer subject to deferral over 8 years.\nGeneral Instructions\nPurpose of Form\nThis form should be used by individual taxpayers and entities \ntaxed like individuals (for example, certain trusts and estates). \nThis form is used to report a taxpayer’s net 965 tax liability for \neach tax year in which a taxpayer must report or pay section 965 \namounts. In addition, this form is used to report the \ndetermination of a taxpayer’s net 965 tax liability, whether or not \nto be paid in installments; the payments of a net 965 tax liability \nto be paid in installments; adjustments of any net 965 tax \nliabilities outstanding, including any net 965 tax liability of the \ntaxpayer that has been assumed by another taxpayer or any net \n965 tax liability that the taxpayer has assumed; an S corporation \nshareholder’s net 965 tax liability with respect to an S \ncorporation, whether or not to be deferred; and the beginning \nbalance of, adjustments to, and ending balance of any deferred \nnet 965 tax liabilities with respect to an S corporation. In \nsummary, this form is intended to be a cumulative report of a \ntaxpayer’s net 965 tax liabilities through payment in full. This \nform must be completed by a taxpayer for every tax year for \nwhich the taxpayer has any net 965 tax liability outstanding and \nnot fully paid at any point during the tax year, including deferred \nnet 965 tax liabilities with respect to an S corporation.\nDefinitions\nDeferred foreign income corporation (DFIC). A DFIC is, with \nrespect to any U.S. shareholder, any specified foreign \ncorporation (as defined under section 965(e)) of a U.S. \nshareholder that has accumulated post-1986 deferred foreign \nincome (as defined under section 965(d)(2)) as of November 2, \n2017, or December 31, 2017, that is greater than zero.\nU.S. shareholder. For tax years of foreign corporations \nbeginning before January 1, 2018, a U.S. shareholder is a U.S. \nperson who owns (directly, indirectly, or constructively) 10% or \nmore of the total combined voting power of all classes of stock of \na foreign corporation. A U.S. person for this purpose is defined \nin section 957(c) of the Code.\nNet income tax liability. The taxpayer’s regular income tax \nliability reduced by the credits allowed under subparts A, B, and \nD of part IV of subchapter A (generally non-refundable credits; \nspecifically, those credits allowed under sections 21 through \n30D and sections 38 through 45T).\nNet 965 tax liability. The excess of the taxpayer’s net income \ntax liability computed with all section 965 amounts included \n(“with calculation”) over the taxpayer’s net income tax liability \nwithout regard to section 965 (“without calculation”). See \nDec 15, 2020\nCat. No. 71280E\n", "Regulations section 1.965-7(g)(10) for rules for computing the \nnet 965 tax liability.\nS corporation-related net 965 tax liability. With respect to an \nS corporation, the excess of the taxpayer’s net income tax \nliability computed with all section 965 amounts included (which, \nin this case, includes only section 965 amounts allocated from \nsuch S corporation with respect to DFICs of which such S \ncorporation is a U.S. shareholder) (“with calculation”) over the \ntaxpayer’s net income tax liability without regard to section 965 \n(“without calculation”).\nReporting year. The tax year of the return with which this form \nis being filed.\nWho Must File\nAny individual taxpayer (or taxpayer taxed like an individual) who \nhas a net 965 tax liability for any tax year or has any net 965 tax \nliability remaining unpaid at any time during a tax year must file \nthis form.\nWhen and Where To File\nFile Form 965-A with the income tax return of the taxpayer for \nthe reporting year by the due date (taking into account \nextensions, if any) of the return.\nElectronic Filing of Form 965-A\nIf you file your income tax return electronically, Form 965-A is \nfiled with the electronic income tax return. See the instructions \nfor your income tax return for general information about \nelectronic filing.\nSpecific Instructions\nAmended Report\nCheck the amended report box at the top of page 1 of the form if \nForm 965-A is filed with an amended return that is filed to \nchange any reporting related to section 965, regardless of \nwhether a Form 965-A has previously been filed. The amended \nreturn box must also be checked for any amended Form 965-A \nfiled with a Form 1045 applying for a tentative refund resulting \nfrom the carryback of an NOL to a section 965 year pursuant to \nsection 172(b)(1)(D)(i).\nPart I – Report of Net 965 Tax Liability \nand Election to Pay in Installments\nLines 1 through 8. Report in Part I net 965 tax liability amounts \nas follows.\nOn lines 1, 2 and 3, you must continue to report 2017, 2018, \nand/or 2019 amounts for all columns, including the original \ncomputation of net 965 tax liability reported in columns (b) \nthrough (i) on a prior-year Form 965-A. Report in column (j) any \ncurrent-year net 965 tax liability transferred out (that is, for which \nyou filed a valid transfer agreement as the transferor) or any \ncurrent tax year subsequent adjustments. Also, complete \ncolumn (k), if applicable.\nFor 2020 tax years, use line 4 to report section 965(a) \ninclusions derived solely through interests in pass-through \nentities that are U.S. shareholders of DFICs.\nUse lines 5 through 8 to report other amounts of net 965 tax \nliability of the taxpayer, such as:\n• Installment liability transfers in. The taxpayer may, in \ncertain circumstances, and by agreement with the Secretary, \nassume as transferee the installment payment liability for the \ntransferor's remaining net 965 tax liability and pay it in the same \nmanner as if the taxpayer were the transferor. (See instructions \nfor Form 965-C for more details.) If this occurs, the transferee \nshould complete one of lines 5 through 8 in Part I as follows:\n• In column (a), enter the tax year of the net 965 tax liability for \nwhich the installment payment liability is being assumed. For \nexample, if a net 965 tax liability incurred in tax year 2017 (with \nrespect to which an installment payment election was made) \nwas transferred to a transferee in 2022, in 2022 the taxpayer \n(transferee) reports “2017” in column (a).\n• Skip columns (b) through (i).\n• In column (j), report, as a positive number, the remaining \ninstallment payment liability (that is, original liability less \npayments made by the transferor) assumed by the taxpayer as \ntransferee.\n• In column (k), report the tax identification number of the \ntransferor.\n• Payments of such liability would then be reported on the \ncorresponding line of Part II in the same manner as if the \ntaxpayer were the transferor.\nFor example, assume Transferor had an original net 965 tax \nliability of $100 in year 1, when an installment payment election \nwas made. In years 1 through 5, Transferor reports payments of \nfive 8% installments. Then, in year 6, the liability to pay the \nremaining installments (15%, 20%, and 25%) totaling $60 is \ntransferred to Taxpayer as transferee. Taxpayer would report on \na line in Part I the tax year of the net 965 tax liability for which the \ninstallment payment liability is being assumed in column (a); the \n$60 amount of the transfer as a positive number in column (j); \nand the tax identification number of Transferor in column (k). In \naddition, on the corresponding line in Part II, Taxpayer would \nreport the $15 installment payment made in column (g), Paid for \nYear 6 (the installment year as if Taxpayer were paying as \nTransferor). In the next reporting year, Taxpayer would report all \nthe same information in Part II, plus the payment of $20 (20% of \nthe original $100 liability) in column (h), Paid for Year 7. In the \nfollowing reporting year, Taxpayer would report all the same \ninformation as in year 7, plus the final payment of $25 (25% of \nthe original $100 liability) in column (i), Paid for Year 8.\n• Triggered deferred S corporation-related net 965 tax \nliability. Deferred S corporation-related net 965 tax liabilities \nbecome subject to payment when a triggering event occurs. \n(See instructions for Part III and Part IV for information \nconcerning the computation, reporting, deferral election, and \ntriggering events for S corporation-related net 965 tax liabilities.) \nWhen such a deferred liability is triggered, it must be transferred \nfrom Part IV, where it is annually reported, to Part I, column (f). \nSuch a triggered S corporation-related net 965 tax liability is \ngenerally eligible for an election to be paid in 8 installments \nbeginning in the year of the triggering event. In the case of a \ntriggering event with respect to a deferred S corporation-related \nnet 965 tax liability, complete one of lines 5 through 8 as follows: \nIn column (a), report the tax year in which the triggering event \noccurred. Skip columns (b) through (e) and report the triggered \nliability in column (f). Report in column (g) whether the taxpayer \nelected to pay the triggered liability in 8 installments by entering \n“Yes” or “No.”\nFor certain triggered net 965 tax liabilities, the taxpayer \nmay elect to pay in installments only with consent of the \nSecretary. (See instructions for Form 965-E for more \ndetails.) Without consent, the taxpayer must enter a checkmark \nin the “No” column of column (g) and enter the amount of the \ntriggered liability in column (h).\n• If the taxpayer does not (or cannot) elect to pay the triggered \ndeferred net 965 tax liability in installments, then report the \namount from column (f) in column (h). This should equal the \npayment reported in the corresponding line of Part II, column (b), \nPaid for Year 1.\n• If the taxpayer elects to pay the triggered liability in \ninstallments, skip column (h) and report the amount from column \nCAUTION\n!\n-2-\nInstructions for Form 965-A (Rev. 01-2021)\n", "(f) in column (i). The corresponding line in Part II, column (b), \nPaid for Year 1, should report an 8% payment of the amount \nelected to be paid in installments. The remaining payments \nshould generally be reported in subsequent reporting years \naccording to the installment schedule. (See instructions for Part \nII, line 1, for the general installment schedule.)\n• If lines 5 through 8 do not provide adequate lines to report all \nthe taxpayer’s transactions described above, an additional Form \n965-A should be used.\nNote. Even if a net 965 tax liability was reported on a taxpayer’s \nincome tax return and fully paid, because no elections were \nmade, the taxpayer must complete the appropriate line in Part I \nand report the related payment on the corresponding line in Part \nII, column (b).\nNote. If an installment election under section 965(h) or a \ndeferral election under section 965(i) was made, then the \ntaxpayer must complete the appropriate line in Part I, as well as \nthe corresponding line in Parts II through IV, as applicable, to \nreport the status of the net 965 tax liability and any related \nadjustments for the reporting year.\nColumn (b). Report the taxpayer’s net income tax liability for \nthe tax year reported in column (a), with all section 965 amounts \nincluded (“with calculation”).\nColumn (c). Report the taxpayer’s net income tax liability for \nthe tax year reported in column (a), without regard to section 965 \n(“without calculation”).\nColumn (d). Report the excess of the taxpayer’s “with \ncalculation” reported in column (b) over the “without calculation” \nreported in column (c). This is the taxpayer’s net 965 tax liability \nfor the tax year reported in column (a).\nColumn (e). If the taxpayer is a shareholder in one or more S \ncorporation(s) with section 965 amounts, report the total of \ncolumn (g) from Part III for the tax year reported in column (a). \nThis is the total S corporation-related net 965 tax liability the \ntaxpayer elected to defer. See detailed instructions for Part III \nregarding the S corporation-by-S corporation calculations and \nelections.\nColumn (f). Report the amount in column (d), less the amount \nin column (e), if any. This is the taxpayer’s net 965 tax liability \neligible for the installment payment election.\nColumn (g). If the taxpayer made an election to pay a net 965 \ntax liability in installments over 8 years as provided for in section \n965(h) and in the manner described in Regulations section \n1.965-7(b)(2), enter a check mark in the “Yes” column. If “Yes,” \nskip column (h) and enter the amount from column (f) in column \n(i). Otherwise, enter a check mark in the “No” column. If “No,” \nenter the amount from column (f) in column (h) and skip column \n(i).\nThe actual payment of the first installment is due no later \nthan the due date of the return for the tax year without \nextension, even if the election is made on a return filed \nby the extended due date.\nColumn (j). Report the following in column (j):\n• Report, as a negative number, any net 965 tax liability for the \nyear reported in column (a) that has been transferred out to a \ntransferee, by agreement with the Secretary, under which the \ntransferee becomes liable for the remaining installments due on \nthe liability in the same manner as if such transferee were the \ntaxpayer. (See instructions for Form 965-C for more details.) In \naddition, provide the tax identification number of the transferee \nin column (k). For example, if the taxpayer (transferor) incurred a \nnet 965 tax liability in tax year 2017, for which an installment \npayment election was made, then properly transferred the \nCAUTION\n!\nliability net of payments previously made, to a transferee in \n2022, the taxpayer (transferor) would report, on line 1, column \n(j), as a negative number, the amount of the net liability \ntransferred out. The making and reporting of payments on such \nliability should generally cease (see instructions for Part II, later).\n• Report any transfer in of a net 965 tax installment payment \nliability from a seller/transferor by a transferee (see the \ninstructions for Lines 1 through 8, earlier).\n• Report subsequent adjustments to the net 965 tax liability for \nthe tax year reported in column (a) for which no amended return \nwas required to be filed, such as an audit adjustment. A liability \nincrease should be reported as a positive number and a \ndecrease as a negative number.\nNote. An adjustment of a net 965 tax liability elected to be paid \nin installments is generally prorated to all installments.\nFor example, for tax year 2017, a taxpayer (TP) reported a \n$100 net 965 tax liability for which an installment election was \nmade. For each of years 1 through 5, TP pays and reports an $8 \ninstallment. Also, in year 5, an audit adjustment increases the \n2017 net 965 tax liability to $150, a $50 positive adjustment. No \namended return was required and there was no negligence, \nintentional disregard, or fraud on the part of TP. This adjustment \nwould be prorated to all the installments. TP would report the \n$50 adjustment in Part I, line 1, column (j), as a positive number, \nso the reported adjusted liability would be $150. In addition, TP \nwould pay and report (in addition to the original $8 installment \nreported for year 5) $20 on Part II, line 1, column (f), \nrepresenting 8% of the adjustment prorated to each of years 1 \nthrough 5, for which the installment due date had already \narrived. For year 6, TP would pay and report $22.50 (15% of the \nadjusted $150 liability); for year 7, $30 (20% of the adjusted \n$150 liability); and for year 8, $37.50 (25% of the adjusted $150 \nliability).\nIn a case in which a net 965 tax liability for a tax year is both \nadjusted and transferred, report the net adjustment/transfer \nnumber in column (j), a transferee tax identification number in \ncolumn (k), and provide a statement, attached to this form, which \nincludes details of the amounts netted in column (j).\nPart II – Record of Amount of Net 965 \nTax Liability Paid by the Taxpayer\nPart II is intended to be a cumulative record of the actual \npayments the taxpayer has made with respect to the net 965 tax \nliabilities reported in Part I.\nLine 1. This line records the actual payments with respect to the \nnet 965 tax liability reported on line 1 of Part I for the tax year \n2017.\nThe general installment payment schedule for a net 965 tax \nliability subject to an election to pay in installments is:\n1.\n8% of the net 965 tax liability payable in year 1 (the year \nof the section 965(a) inclusion or triggering event with respect to \na deferred S corporation-related net 965 tax liability),\n2.\n8% of the net 965 tax liability payable in year 2,\n3.\n8% of the net 965 tax liability payable in year 3,\n4.\n8% of the net 965 tax liability payable in year 4,\n5.\n8% of the net 965 tax liability payable in year 5,\n6.\n15% of the net 965 tax liability payable in year 6,\n7.\n20% of the net 965 tax liability payable in year 7, and\n8.\n25% of the net 965 tax liability payable in year 8.\nIf, for any reason, the actual payment differs from the \nschedule, report the actual payment made.\nExample. If the reporting year is 2020 and the taxpayer is \nreporting a 2017 net 965 tax liability for which an installment \nInstructions for Form 965-A (Rev. 01-2021)\n-3-\n", "payment election was made, because the 2020 reporting year is \n“Year 4” with respect to a 2017 net 965 tax liability being paid in \ninstallments, installment payments reported in Part II on line 1, \nthe line for 2017, should generally be:\n• In column (b), Paid for Year 1, report 8% of the 2017 net 965 \ntax liability;\n• In column (c), Paid for Year 2, report 8% of the 2017 net 965 \ntax liability;\n• In column (d), Paid for Year 3, report 8% of the 2017 net 965 \ntax liability; and\n• In column (e), Paid for Year 4, report 8% of the 2017 net 965 \ntax liability.\nColumn (a). Report the tax year of the section 965(a) inclusion, \nthe net 965 tax liability for which an installment payment liability \nis being assumed, or triggering event with respect to a deferred \nS corporation-related net 965 tax liability, as reported on the \ncorresponding line of Part I, column (a).\nColumns (b) through (i). These columns are used to record \nthe taxpayer’s cumulative payments, made each reporting year, \nfor the net 965 tax liability reported on the corresponding line in \nPart I.\nIf no installment election is made, the net 965 tax liability \nreported in Part I, column (h), should be paid and reported on \nthe corresponding line of Part II, column (b), Paid for Year 1, and \nthe remaining payment columns (c) through (i) left blank.\nIf an installment election is made, and no transfers, \nacceleration events, or adjustments occur during the 8-year \ninstallment period, then 8% of the net 965 tax liability should be \npaid and reported in column (b), Paid for Year 1 (the year of the \ninstallment payment election). In the next reporting year, the \nrelevant information from the prior reporting year should be \ncarried forward, plus 8% of the net 965 tax liability should be \npaid and reported in column (c), Paid for Year 2. In future \nreporting years, the payments and payment reporting should \ncontinue similarly in accordance with the general installment \npayment schedule described above.\nIf the taxpayer transfers out a net 965 tax liability, then the \nmaking and reporting of installment payments should generally \ncease for the transferred net 965 tax liability in the year of \ntransfer. However, reporting with respect to the net 965 tax \nliability is still required for the reporting year if any net 965 tax \nliability of the taxpayer remains unpaid at any time during the \nreporting year.\nIf an acceleration event occurs, then the unpaid portion of all \nremaining installments is due on the date of the acceleration \nevent and should be paid and reported in the column for the year \nin which the acceleration event occurs; however, reporting with \nrespect to the net 965 tax liability is still required for the reporting \nyear if any net 965 tax liability of the taxpayer remains unpaid at \nany time during the reporting year.\nIf an adjustment occurs to a net 965 tax liability for which an \ninstallment election has been made, including on an amended \nreturn, the adjustment should generally be prorated over all the \ninstallment payments. For the part of the adjustment prorated to \ninstallments whose payment date has already arrived, adjust the \npayment for the reporting year in which the adjustment is made \nand report accordingly. For the part of the adjustment prorated to \ninstallments for which the payment date has not yet arrived, pay \nand report in accordance with the installment schedule.\nPayments should include both actual installment payments \nmade and excess payments of other income tax liabilities \napplied to the taxpayer’s net 965 tax liability.\nColumn (j). Report the net 965 tax liability remaining unpaid \nafter the payment for the reporting year. This amount should \nequal the amount reported on the corresponding line in Part I, \ncolumn (f), or column (i), as applicable, plus or minus any \namount reported on the corresponding line in Part I, column (j), \nless any payments reported in Part II, columns (b) through (i).\nColumn (k). For each line, report only the payment made (if \nany) for the reporting year.\nCurrent-year reporting of column (k) amounts:\nIndividuals: For tax year 2020, enter the amount from Form \n965-A, Part II, column (k), line 4, on Schedule 2 (Form 1040), \nline 9.\nAll others: For all other filers (that is, other taxpayers taxed like \nan individual), follow the form instructions for that other \napplicable return.\nPart III – S Corporation Shareholder: \nReport of Calculation of Net 965 Tax \nLiability Related to 965 Amounts \nAllocated from an S Corporation and \nElection To Defer Such Net 965 Tax \nLiability\nThis Part allows a taxpayer that is an S corporation shareholder \nto report net 965 tax liabilities related to section 965 amounts \nwith respect to S corporations. For each S corporation-related \nnet 965 tax liability, the taxpayer may elect to defer payment of \nsuch liability until a triggering event occurs. (See instructions for \nPart IV for more information on triggering events.) Each S \ncorporation-related net 965 tax liability is calculated on an \nindividual S corporation basis, and an election to defer such \nliability is also made on an individual S corporation basis. Such \nliabilities deferred, if any, must be totaled by tax year, and the \ntotal carried to Part I, column (e), of the respective tax year line.\nLines 1 through 4. Report S corporation-related net 965 tax \nliabilities for the tax year indicated. On lines 1, 2 and 3, you must \ncontinue to report 2017, 2018, and/or 2019 amounts for all \ncolumns, even though they were reported on a prior-year Form \n965-A. Space is provided for reporting net 965 tax liabilities \nrelated to up to four S corporations. If additional lines are needed \nfor the tax year, use additional Forms 965-A.\nColumn (a). Report the name of the S corporation from which \nthe taxpayer is allocated section 965 amounts. Abbreviate as \nneeded.\nColumn (b). Report the tax identification number of the S \ncorporation reported in column (a). The tax identification number \nof an S corporation is its employer identification number (EIN).\nColumn (c). Report the taxpayer’s net income tax for the tax \nyear calculated only with section 965 amounts allocated from \nthis S corporation with respect to DFICs of which the S \ncorporation is a U.S. shareholder. This is the S \ncorporation-related “with calculation.”\nColumn (d). Report the taxpayer’s net income tax for the tax \nyear calculated without regard to section 965, that is, the \n“without calculation.” This should equal the taxpayer’s net tax \nliability without section 965 amounts for the corresponding tax \nyear reported in Part I, column (c).\nColumn (e). Report the excess of the taxpayer’s S \ncorporation-related “with calculation” reported in column (c) over \nthe “without calculation” reported in column (d). This is the \ntaxpayer’s S corporation-related net 965 tax liability with respect \nto this S corporation for the tax year.\nColumn (f). If the taxpayer made an election to defer payment \nof this S corporation-related net 965 tax liability as provided for in \nsection 965(i) and in the manner described in Regulations \nsection 1.965-7(c)(2), enter a check mark in the “Yes” column. \nOtherwise, enter a check mark in the \"No\" column.\n-4-\nInstructions for Form 965-A (Rev. 01-2021)\n", "Column (g). If the taxpayer elected to defer an S \ncorporation-related net 965 tax liability, enter the amount from \ncolumn (e). (If the election was not made, then the liability \nremains a part of the taxpayer’s total net 965 tax liability subject \nto an installment payment election.) The total of column (g) for a \ntax year represents the taxpayer’s total deferred S \ncorporation-related net 965 tax liability for the tax year and \nshould be entered on the corresponding tax year line in Part I, \ncolumn (e).\nPart IV – Annual Report of Deferred \nNet 965 Tax Liability Related to 965 \nAmounts Allocated from S \nCorporations\nAny shareholder of an S corporation that makes an election to \ndefer payment of an S corporation-related net 965 tax liability \nmust report such liability with their income tax return for the year \nof election and every year thereafter through the year in which \nsuch amount is fully paid. Part IV provides for the required \nannual reporting of deferred S corporation-related net 965 tax \nliabilities and any adjustments related to such deferred liabilities \nduring the reporting year.\nIf the taxpayer fails to report for any year information \nrequired to be reported under section 965(i)(7) by the \ndue date of the return for such year, 5% of the deferred \nnet 965 tax liability shall be assessed as an addition to tax for \nsuch reporting year.\nColumn (a). Report the year of:\n• Deferral election. In a year for which an election is made to \ndefer an S corporation-related net 965 tax liability, any amounts \nelected to be deferred must be transferred from Part III, column \n(g), to the corresponding line in Part IV, column (d). Enter the \nyear for which the election is made in column (a) of the \ncorresponding line.\n• Transfer in. In certain circumstances, by agreement with the \nSecretary, a taxpayer may assume a deferred S \ncorporation-related net 965 tax liability from another taxpayer \nwho had elected to defer such amount. The transferee is liable \nfor the deferred S corporation-related net 965 tax liability in the \nsame manner as the transferor, including being subject to \nannual reporting requirements. (See instructions for Form 965-D \nfor more details.) Enter the tax year of transfer in column (a). See \nthe instructions for Part IV, column (g), later, for reporting the \namount of the transfer in.\nColumn (b). Report the name of the S corporation to which the \ndeferred net 965 tax liability relates. Abbreviate as needed.\nColumn (c). Report the tax identification number of the S \ncorporation reported in column (b). The tax identification number \nof an S corporation is its employer identification number (EIN).\nColumn (d). Report the beginning deferred S \ncorporation-related net 965 tax liability.\n• For the year of the deferral election, this amount will be the S \ncorporation-related net 965 tax liability for which the taxpayer \nelects to defer payment and should be transferred from the \ncorresponding line for such S corporation in Part III, column (g).\n• For subsequent reporting years, the amount reported should \nequal the amount on the corresponding line in column (i) from \nPart IV of Form 965-A for the prior reporting year.\n• For assumptions of deferred S corporation-related net 965 tax \nliabilities, by agreement with the Secretary, the amount reported \nshould equal the amount of S corporation-related net 965 tax \nliability assumed by the taxpayer.\nColumn (e). Reserved for future use.\nCAUTION\n!\nColumn (f). Report the amount of each deferred S \ncorporation-related net 965 tax liability, payment of which \nceases to be deferred as a result of a triggering event during the \nreporting year (“triggered S corporation-related net 965 tax \nliability”). The triggered S corporation-related net 965 tax liability \namount should be reported in column (f) as a negative number \nand transferred to column (f) on one of lines 5 through 8 in Part I \nas a positive number. See Triggered deferred S \ncorporation-related net 965 tax liability, in the instructions for \nPart I, lines 1 through 8, earlier.\nColumn (g). Report the amount of deferred S \ncorporation-related net 965 tax liability transferred out or in.\nTransfers (out). When a taxpayer transfers stock of an S \ncorporation with respect to which the taxpayer has made an \nelection to defer payment of its S corporation-related net 965 tax \nliability, the transfer is not treated as a triggering event if the \ntransferee, by agreement with the Secretary, becomes liable for \nthe deferred S corporation-related net 965 tax liability in the \nsame manner as the transferor. (See instructions for Form 965-D \nfor more details.)\nReport the amount of the transfer out as a negative number in \ncolumn (g) of the same line as the taxpayer reported the \ndeferred S corporation-related net 965 tax liability at the \nbeginning of the reporting year.\nIn a case of multiple transferees, report the total deferred S \ncorporation-related net 965 tax liability transferred as a negative \nnumber in column (g) and in column (h) report the tax \nidentification number of a transferee and attach a schedule to \nForm 965-A providing a breakdown of the total deferred S \ncorporation-related net 965 tax liability transferred and the \nassociated tax identification numbers of each transferee.\nTransfers in. A taxpayer may assume, by agreement with the \nSecretary, a deferred 965 net tax liability as a buyer/transferee of \nS corporation stock with respect to which the transferor has a \ndeferred S corporation-related net 965 tax liability. The taxpayer \nwill then be liable for the deferred S corporation-related net 965 \ntax liability in the same manner as the transferee, including being \nsubject to annual reporting requirements, beginning for the tax \nyear of transfer. (See instructions for Form 965-D for more \ndetails.) For the year of transfer, a new line in Part IV must be \ncompleted, skipping columns (d), (e), and (f), and entering in \nboth columns (g) and (i) the deferred S corporation-related net \n965 tax liability transferred in as a positive number.\nFor reporting years following the year of transfer, report the \ntransferred deferred S corporation-related net 965 tax liability in \nthe same fashion as all other deferred S corporation-related net \n965 tax liabilities.\nColumn (h). Provide the tax identification number of the \ntransferee or transferor.\nColumn (i). For each line, combine the amounts reported in \ncolumns (d) through (g).\nPaperwork Reduction Act Notice\nWe ask for the information on this form to carry out the Internal \nRevenue laws of the United States. You are required to give us \nthe information. We need it to ensure that you are complying \nwith these laws and to allow us to figure and collect the right \namount of tax.\nYou are not required to provide the information requested on \na form that is subject to the Paperwork Reduction Act unless the \nform displays a valid OMB control number. Books or records \nrelating to a form or its instructions must be retained as long as \ntheir contents may become material in the administration of any \nInternal Revenue law. Generally, tax returns and return \ninformation are confidential, as required by section 6103.\nInstructions for Form 965-A (Rev. 01-2021)\n-5-\n", "The time needed to complete and file this form will vary \ndepending on individual circumstances. The estimated burden \nfor individual taxpayers filing this form is approved under OMB \ncontrol number 1545-0074 and is included in the estimates \nshown in the instructions for their individual income tax return.\n-6-\nInstructions for Form 965-A (Rev. 01-2021)\n" ]
f5471sr.pdf	1220 Form 5471 (Schedule R) (PDF)	https://www.irs.gov/pub/irs-pdf/f5471sr.pdf	[ "SCHEDULE R \n(Form 5471)\n(December 2020)\nDepartment of the Treasury \nInternal Revenue Service\nDistributions From a Foreign Corporation\n▶ Attach to Form 5471.\n▶ Go to www.irs.gov/Form5471 for instructions and the latest information.\nOMB No. 1545-0123\nName of person filing Form 5471\nIdentifying number\nName of foreign corporation\nEIN (if any)\nReference ID number (see instructions)\n(a) Description of distribution\n(b) \nDate of distribution\n(c) Amount of \ndistribution in \nforeign \ncorporation’s \nfunctional currency\n(d) Amount of E&P \ndistribution in \nforeign \ncorporation’s \nfunctional currency\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\nFor Paperwork Reduction Act Notice, see instructions.\nCat. No. 73415F\nSchedule R (Form 5471) (12-2020)\n" ]
i8975.pdf	1220 Inst 8975 (PDF)	https://www.irs.gov/pub/irs-pdf/i8975.pdf	[ "Instructions for Form 8975 \nand Schedule A (Form 8975)\n(Rev. December 2020)\nCountry-by-Country Report\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nFor the latest information about developments related to \nForm 8975, Schedule A (Form 8975), and their instructions, \nsuch as legislation enacted after they were published, go to \nIRS.gov/Form8975.\nGeneral Instructions\nPurpose of Form\nCertain U.S. persons that are the ultimate parent entity of a \nU.S. multinational enterprise (U.S. MNE) group with annual \nrevenue for the preceding reporting period of $850 million or \nmore are required to file Form 8975.\nForm 8975 and Schedules A (Form 8975) are used by \nfilers described under Who Must File to annually report \ncertain information with respect to the filer’s U.S. MNE group \non a country-by-country basis. The filer must list the U.S. \nMNE group’s constituent entities, indicating each entity’s tax \njurisdiction (if any), country of organization and main \nbusiness activity, and provide financial and employee \ninformation for each tax jurisdiction in which the U.S. MNE \ndoes business. The financial information includes revenues, \nprofits, income taxes paid and accrued, stated capital, \naccumulated earnings, and tangible assets other than cash.\nForm 8975 and its Schedules A (Form 8975) must be filed \nwith the IRS with the income tax return of the ultimate parent \nentity of a U.S. MNE group for the tax year in or within which \nthe reporting period covered by the Form 8975 ends.\nDo not file Form 8975 and its Schedules A (Form \n8975) separately from your income tax return.\nDefinitions\nFor more information on the terms below, see Regulations \nsection 1.6038-4.\nApplicable financial statement. An applicable financial \nstatement is a certified audited financial statement that is \naccompanied by a report of an independent certified public \naccountant or similarly qualified independent professional \nthat is used for purposes of reporting to shareholders, \npartners, or similar persons; for purposes of reporting to \ncreditors in connection with securing or maintaining \nfinancing; or for any other substantial nontax purpose.\nBusiness entity. A business entity is generally any entity \nrecognized for federal tax purposes that is not properly \nclassified as a trust under Regulations section 301.7701-4. \nHowever, any grantor trust within the meaning of section 671, \nall or a portion of which is owned by a person other than an \nindividual, is considered a business entity.\nCAUTION\n!\nAdditionally, the term “business entity” includes any entity \nwith a single owner that may be disregarded as an entity \nseparate from its owner under Regulations section \n301.7701-3, and any permanent establishment (described \nbelow) that prepares financial statements separate from \nthose of its owner for financial or tax reporting, regulatory, or \ninternal management control purposes.\nA decedent's estate or a bankruptcy estate described in \nsection 1398 is not a business entity.\nConstituent entity. With respect to a U.S. MNE group, a \nconstituent entity is any separate business entity of such U.S. \nMNE group but does not include a foreign corporation or \nforeign partnership for which information is not otherwise \nrequired to be furnished under section 6038(a) (determined \nwithout regard to Regulations sections 1.6038-2(j) and \n1.6038-3(c)) or any permanent establishment of such foreign \ncorporation or foreign partnership.\nPermanent establishment (PE). The term “permanent \nestablishment” includes:\n• A branch or business establishment of a constituent entity \nin a tax jurisdiction that is treated as a permanent \nestablishment under an income tax convention to which that \ntax jurisdiction is a party,\n• A branch or business establishment of a constituent entity \nthat is liable to tax in the tax jurisdiction in which it is located \npursuant to the domestic law of such tax jurisdiction, or\n• A branch or business establishment of a constituent entity \nthat is treated in the same manner for tax purposes as an \nentity separate from its owner by the owner's tax jurisdiction \nof residence.\nReporting period. The reporting period covered by Form \n8975 and Schedules A (Form 8975) is generally the \n12-month period of your applicable financial statement that \nends with or within your tax year. If you do not prepare an \nannual applicable financial statement, then the reporting \nperiod covered by Form 8975 and Schedules A (Form 8975) \nis generally the 12-month period that ends on the last day of \nyour tax year.\nTax jurisdiction. A tax jurisdiction is a country or a \njurisdiction that is not a country but that has fiscal autonomy. \nA U.S. territory or possession of the United States is \nconsidered to have fiscal autonomy.\nTax jurisdiction of residence. A business entity is \ngenerally considered a resident in a tax jurisdiction if, under \nthe laws of that tax jurisdiction, the business entity is liable for \ntax therein based on place of management, place of \norganization, or another similar basis. A business entity is not \nconsidered a tax resident in a tax jurisdiction if the business \nentity is liable for tax in such tax jurisdiction only by reason of \na tax imposed by reference to gross amounts of income \nwithout any reduction for expenses, provided such tax \napplies only with respect to income from sources in such tax \njurisdiction or capital situated therein.\nSep 10, 2020\nCat. No. 69160R\n", "A corporation that is organized or managed in a tax \njurisdiction that does not impose an income tax on \ncorporations will be treated as resident in that tax jurisdiction, \nunless such corporation is treated as resident in another tax \njurisdiction under the previously described rules.\nThe tax jurisdiction of residence of a permanent \nestablishment is the jurisdiction in which the permanent \nestablishment is located.\nA business entity that does not have a tax jurisdiction of \nresidence is considered “stateless.”\nUltimate parent entity of a U.S. MNE group. The ultimate \nparent entity of a U.S. MNE group is a U.S. business entity \nthat:\n• Owns directly or indirectly a sufficient interest in one or \nmore other business entities, at least one of which is \norganized or tax resident in a tax jurisdiction other than the \nUnited States, such that the U.S. business entity is required \nto consolidate the accounts of the other business entities \nwith its own accounts under U.S. GAAP (or that would be so \nrequired if publicly traded); and\n• Is not owned directly or indirectly by another business \nentity that consolidates the accounts of such U.S. business \nentity with its own accounts under GAAP in the other \nbusiness entity's tax jurisdiction of residence (or that would \nbe so required if publicly traded in its tax jurisdiction of \nresidence).\nU.S. business entity. A U.S. business entity is a business \nentity that is organized or has its tax jurisdiction of residence \nin the United States. Foreign insurance companies that elect \nto be treated as domestic corporations under section 953(d) \nare U.S. business entities that have their tax jurisdiction of \nresidence in the United States. A business entity that is a \nlimited liability company that is organized in the United \nStates, and is wholly owned (directly) by another business \nentity that has its tax jurisdiction of residence and is \norganized in the United States, will be considered a U.S. \nbusiness entity that has its tax jurisdiction of residence in the \nUnited States.\nU.S. MNE group. A U.S. MNE group comprises the ultimate \nparent entity of a U.S. MNE group and all of the business \nentities required to consolidate their accounts with the \nultimate parent entity's accounts under U.S. GAAP (or that \nwould be so required if publicly traded), regardless of \nwhether any such business entities could be excluded from \nconsolidation solely on size or materiality grounds.\nBusiness entities are not considered part of the U.S. MNE \ngroup if the income or assets of the business entities are \nincluded in the financial statements of the ultimate parent \nentity based on the equity method or fair value accounting.\nU.S. territory or possession of the United States. The \nterm “U.S. territory or possession of the United States” \nmeans American Samoa, Guam, the Northern Mariana \nIslands, Puerto Rico, and the U.S. Virgin Islands.\nU.S. territory ultimate parent entity. A U.S. territory \nultimate parent entity is a business entity organized in a U.S. \nterritory or possession of the United States that controls (as \ndefined in section 6038(e)) a U.S. business entity and that is \nnot owned directly or indirectly by another business entity \nthat consolidates the accounts of the U.S. territory ultimate \nparent entity with its accounts under GAAP in the other \nbusiness entity's tax jurisdiction of residence (or would be so \nrequired if equity interests in the other business entity were \ntraded on a public securities exchange in its tax jurisdiction of \nresidence).\nWho Must File\nA U.S. person must file Form 8975 and Schedules A (Form \n8975) if it is the ultimate parent entity of a U.S. MNE group \nwith revenues of $850 million or more in the immediately \npreceding reporting period. A U.S. territory ultimate parent \nentity may designate a U.S. business entity to file on its \nbehalf.\nWhen making the determination of whether you are the \nultimate parent entity of a U.S. MNE group, a business \nentity’s tax jurisdiction of residence is the business entity’s \ncountry of organization if the business entity does not \notherwise have a tax jurisdiction of residence.\nExceptions from filing. You are not required to file Form \n8975 if the annual revenue of your group for the immediately \npreceding reporting period was less than $850 million.\nWhen To File\nAttach Form 8975 and Schedules A (Form 8975) to your \nincome tax return and file them with the IRS by the due date \n(including extensions) for that income tax return. The Form \n8975 and Schedules A (Form 8975) should be attached, as \napplicable, to Forms 1120, 1120-C, 1120-RIC, 1065, 1120-S, \n1120-L, 1120-PC, 1120-REIT, 990-T, and 1041.\nExtension of time to file. To request an extension of time \nto file Form 8975, you must follow the instructions for the \nincome tax return to which Form 8975 and Schedules A \n(Form 8975) will be attached.\nHow To File\nElectronic Filing\nIf you file your income tax return electronically, see the \ninstructions for the income tax return for general information \nabout electronic filing.\nIf you are filing Forms 1120, 1065, 1120-S, 990-T, or 1041 \nelectronically, you must attach Form 8975 and Schedules A \n(Form 8975) electronically in the correct format, not as a \nbinary attachment.\nNote. Beginning January 2021, Form 990-T can be filed \nelectronically.\nNote. In order to ensure the timely automatic exchange of \nthe information on Form 8975 and Schedules A (Form 8975), \nyou are encouraged to file your return electronically. In \ncertain cases, you are required to file your return \nelectronically.\nAmended Form 8975. If you file a Form 8975 and \nSchedules A (Form 8975) that you later determine should be \namended, file an amended Form 8975 and all Schedules A \n(Form 8975), including any that have not been amended, \nwith an amended tax return. Use the amended return \ninstructions for the return with which you originally filed Form \n8975 and Schedules A (Form 8975) and check the amended \nreport checkbox at the top of Form 8975.\nIf the return and Form 8975 that you are amending were \nfiled electronically with the IRS, then the amended return and \nForm 8975 should be filed electronically with the IRS in order \nto ensure timely automatic exchange of the information on \nForm 8975 and Schedules A (Form 8975).\n-2-\nInstructions for Form 8975 (Rev.12-2020)\n", "Where To File\nWhile most entities will be electronically filing their country-by \ncountry reports, some filers will not be able to file \nelectronically. This includes those filing Form 1120-REIT, \nfilers of Forms 1120-C, 1120-L, 1120-PC, and 1120-RIC that \nare filing as parent entities, and filers of Form 1041 that \nchoose not to or are not required to file electronically. These \nfilers should use the mailing addresses provided for the \napplicable income tax return. The Form 8975 and Schedules \nA (Form 8975) must be attached to the applicable paper tax \nreturn.\nPaper-filed returns. If filing on paper only, mail a copy of \npage 1 of your Form 8975 to the IRS. Mailing a copy of \npage 1 of Form 8975 will notify the IRS that you have filed \nForm 8975 and Schedules A (Form 8975) with a paper return \nand will assist the IRS in identifying paper returns that have \nForm 8975 and Schedules A (Form 8975) attached. Mail to \nthe following address:\nInternal Revenue Service\nMailstop 4950\n1973 N. Rulon White Blvd.\nOgden, UT 84201\nRecord Maintenance\nYou are required to maintain records to support the \ninformation provided on Form 8975 and Schedules A (Form \n8975). However, you are not required to create and maintain \nrecords that reconcile the amounts provided on Form 8975 \nand Schedules A (Form 8975) with the income tax returns of \nany tax jurisdiction or your applicable financial statements.\nPenalties for Failure To File\nPenalties under section 6038(b) may apply for failure to \nreport the information required on this form.\nSpecific Instructions for Form \n8975\nThere are two parts to Form 8975. You must complete the \ninformation at the top of the form regarding reporting period \nand Part I. Completing Part II is optional.\nAt the top of Form 8975, enter the reporting period for which \nyou are filing.\nIf filing an amended report (see Amended Form 8975, \nearlier), check the amended report box.\nEnter the number of Schedules A (Form 8975) attached to \nForm 8975. You must attach at least one Schedule A (Form \n8975) to your Form 8975 for each tax jurisdiction in which \nyour group operates, including the United States. Therefore, \nyou will file a separate Schedule A (Form 8975) for at least \ntwo tax jurisdictions.\nGenerally, at least one Schedule A (Form 8975) will be for \nthe United States. However, certain U.S. MNE groups may \nhave only U.S.-organized constituent entities that are fiscally \ntransparent. These fiscally transparent U.S. business entities \ndo not have a tax jurisdiction of residence for purposes of \nreporting information on Form 8975. Thus, these fiscally \ntransparent U.S. business entities, along with all other \nconstituent entities of the U.S. MNE group that do not have a \ntax jurisdiction of residence, should be reported on one \nSchedule A (Form 8975) that indicates the tax jurisdiction \n“stateless.”\nIf a filer does not have either a U.S. Schedule A (Form 8975) \nor a “stateless” Schedule A (Form 8975) that contains fiscally \ntransparent U.S. business entities, then the Form 8975 has \nnot been completed properly.\nPart I—Identification of Filer\nUse Part I to provide your identifying information.\nLine 1a. Enter your complete legal name.\nLine 1b. You are the reporting entity. Enter the code for your \nreporting role. The reporting role indicates whether you are \nfiling as the ultimate parent entity of your group (enter code: \nULT) or if you are filing because you were designated by a \nU.S. territory ultimate parent entity to file on its behalf (enter \ncode: SUR).\nLine 1c. Enter your employer identification number (EIN).\nLines 2 and 3a through 3c. Enter your legal address. \nInclude the suite, room, or other unit number after the street \naddress. If the post office does not deliver mail to the street \naddress and you have a P.O. box, show the box number \ninstead.\nForeign address. Follow the country's practice for \nentering the postal code, if any. Do not abbreviate the \ncountry name.\nLine 4. Enter the common name of the U.S. MNE group if it \nis significantly different from the reporting entity's name on \nline 1a.\nPart II—Additional Information\nYou can enter additional information related to your group, \nsuch as a narrative description of the overall business \noperations and structure of your group or an overall \nassumption or convention that you used which might have an \neffect on your report. Any financial amounts entered in Part II \nmust be stated in U.S. dollars. You will have an opportunity to \nenter specific information regarding financial information and \nconstituent entities in each tax jurisdiction on the appropriate \nSchedule A (Form 8975).\nIf the additional information you choose to enter in Part II \nwill not fit in the allotted space, complete as many additional \npage 2, Part II, Additional Information sections as you need, \nand submit these additional page(s) with Form 8975.\nNote. If the common name of the U.S. MNE group is \nsignificantly different from the reporting entity’s name, explain \nin the Additional Information section.\nSpecific Instructions for Schedule A \n(Form 8975)\nYou must file a separate Schedule A (Form 8975) for each \ntax jurisdiction in which your group has one or more \nconstituent entities resident. If you have any constituent \nentities in your group that do not have a tax jurisdiction of \nresidence (that is, the constituent entity is “stateless”), then \nyou must also fill out a Schedule A (Form 8975) providing the \ninformation for each constituent entity that is stateless, \nreporting the financial and employee information in the \naggregate with respect to those stateless constituent entities, \nand indicating that there is no tax jurisdiction by providing the \nappropriate “stateless” code. See Tax jurisdiction under Part \nI—Tax Jurisdiction Information, later.\nInstructions for Form 8975 (Rev.12-2020)\n-3-\n", "The financial amounts furnished should be based on \napplicable financial statements, books and records \nmaintained with respect to the constituent entities, regulatory \nfinancial statements, or records used for tax reporting or \ninternal management control purposes for an annual period \nof each constituent entity ending with or within the reporting \nperiod.\nAt the top of each Schedule A (Form 8975), enter the \nreporting period, your name, and EIN. These should match \nthe information entered on Form 8975.\nIf a constituent entity in your group is the owner of another \nconstituent entity in your group that is stateless, then the \nowner's share of such stateless entity's revenues and profits \nshould be aggregated with the information for the owner's tax \njurisdiction of residence.\nAt each level, the owner entity includes its share of the \nstateless entity’s revenue and profits in the owner’s tax \njurisdiction of residence only if the owner has a tax \njurisdiction of residence (that is, only if the owner is not \nstateless), and the amount of revenue of the top-tier stateless \nentity from which the owner entity calculates its share should \ninclude any allocations from stateless entities owned, directly \nor indirectly, by the top-tier stateless entity, even if such \nallocations are excluded from the intermediate stateless \nentity’s revenue and profit.\nExample. Assume US Corp is the ultimate parent entity \nof a U.S. MNE group. US Corp owns 90% of partnership P1, \nwhich in turn owns 80% of partnership P2. Both P1 and P2 \ndo not have a tax jurisdiction of residence (that is, they are \nstateless), each earns $100 of revenue and has no expenses \n(P1’s $100 of revenue does not include its allocable share of \nP2’s revenue), and neither creates a permanent \nestablishment (that is, taxable presence) in any tax \njurisdiction. Assume US Corp earns $100 of revenue, not \nincluding its share of P1’s revenue, and has no expenses.\nP2 has $100 of revenue and profit that is reflected on the \nstateless Schedule A (Form 8975) revenue and profit lines. \nP1 has $100 of revenue and profit that is reflected on the \nstateless Schedule A (Form 8975) revenue and profit lines. \nSince P1 is stateless, it does not include its share of P2’s \nrevenue and profit again on the stateless Schedule A (Form \n8975) revenue or profit lines. The total revenue and profit on \nthe stateless Schedule A (Form 8975) is $200.\nUS Corp has $100 of revenue and profit, not including any \nallocations from other constituent entities. Since US Corp \nhas a tax jurisdiction of residence, it includes its share of P1’s \nrevenue and profit on the Schedule A (Form 8975) for the \nUnited States. P1’s revenue and profit, of which US Corp is \nallocated 90%, includes any allocations from stateless \nentities that P1 owns, even if such allocations were not \nincluded on the stateless Schedule A (Form 8975) revenue \nor profit lines. P1’s revenue and profit when determining US \nCorp’s allocable share is $180 (P1’s own $100 of revenue \nand profit plus 80% of P2’s revenue and profit, or $80). US \nCorp is allocated 90% of $180, or $162, of revenue and profit \ndue to its ownership of P1. The total revenue and profit on \nthe United States Schedule A (Form 8975) revenue and profit \nlines is US Corp’s own revenue and profit of $100 plus its \nallocation of $162 of revenue and profit from P1, or $262.\nCurrency Translation\nAll currency amounts furnished must be in U.S. dollars. If an \nexchange rate is used other than in accordance with U.S. \nGAAP for translation to U.S. dollars, the exchange rate must \nbe indicated in Part III, Additional Information, on the \nSchedule A (Form 8975) relating to the amounts that are not \ntranslated in accordance with U.S. GAAP.\nMultiple Schedules A (Form 8975) for a Single \nTax Jurisdiction\nIf you are filing on paper and the information you want to \nenter for a single tax jurisdiction does not fit on a single \nSchedule A (Form 8975), you can attach additional \nSchedules A (Form 8975). Complete the additional \nSchedules A (Form 8975) as follows.\nAbove Part I. Enter the reporting period beginning and \nending dates, the name of the reporting entity, and the EIN.\nPart I. Enter the tax jurisdiction only. Do not complete lines \n1 through 8 of Part I.\nPart II. Complete Part II as needed to list all of the \nconstituent entities resident in the tax jurisdiction.\nPart III. Enter a statement that indicates this is a \ncontinuation sheet, the tax jurisdiction to which the \ncontinuation sheet applies, and the page number of the \ncontinuation sheets (for example, “Page 3 of 9”). Complete \nthe rest of Part III as necessary.\nPart I—Tax Jurisdiction Information\nFor each tax jurisdiction in which one or more constituent \nentities of your group is tax resident, you must provide \nfinancial amounts and number of employees as an aggregate \nof the information for the constituent entities resident in that \ntax jurisdiction.\nTax jurisdiction. This field is mandatory. Enter the \ntwo-letter code for the tax jurisdiction to which the \nSchedule A (Form 8975) pertains. The country code for the \nUnited States is “US” and the country code for “stateless” is \n“X5.” All other country codes can be found at IRS.gov/\nCountryCodes.\nForm 8975 and Schedule A (Form 8975) information is \nexchanged using the OECD Country Code List that is based \non the ISO 3166-1 Standard. Although the country codes \nfound in the IRS link above contain the jurisdictions listed in \nthe table below, those jurisdictions do not correspond to a \nvalid OECD country code for purposes of exchanging the \ninformation. Therefore, do not enter any of these country \ncodes on the tax jurisdiction line of Part I of Schedule A \n(Form 8975).\nTax Jurisdiction\nCountry Code\nAkrotiri\nAX\nAshmore and Cartier Islands\nAT\nClipperton Island\nIP\nCoral Sea Islands\nCR\nDhekelia\nDX\nParacel Islands\nPF\nSpratly Islands\nPG\nIf the tax jurisdiction specified in the above list is \nassociated with a larger sovereignty, use the country code for \nthe larger sovereignty with which the tax jurisdiction is \nassociated (for example, Akrotiri and Dhekelia are \nconsidered a British Overseas Territory so the country code \nfor the United Kingdom would be used (“UK”)). Otherwise, \n-4-\nInstructions for Form 8975 (Rev.12-2020)\n", "use a separate Schedule A (Form 8975) for “other country” \nusing the tax jurisdiction code “OC.” In either case, you \nshould include in Part III of Schedule A (Form 8975) the \nname of the specific constituent entity and the jurisdiction \nwhere the constituent entity is located.\nWhen you enter a country code in Schedule A (Form \n8975), Part I, the financial and employee information \nin Part I, the constituent entity information in Part II, \nand the additional information in Part III, must pertain to the \nconstituent entities that are tax resident in that jurisdiction.\nIn Part I, you will provide the aggregate amounts for all of \nthe constituent entities listed in Part II.\nLines 1a through 1c. On line 1a, enter the aggregate \nrevenues of the constituent entities listed in Part II that are \ngenerated from transactions with those that are not \nconstituent entities in your group. On line 1b, enter the \naggregate revenues of the constituent entities listed in Part II \nthat are generated from transactions with other constituent \nentities in your group. On line 1c, enter the total aggregate \nrevenues of the constituent entities listed in Part II.\nThe term “revenue” includes all amounts of revenue, \nincluding revenue from sales of inventory and property, \nservices, royalties, interest, and premiums.\nRevenue does not include payments received from other \nconstituent entities in your group that are treated as \ndividends in the payor's tax jurisdiction of residence. \nDistributions and remittances from your constituent entities \nthat are partnerships, other fiscally transparent entities, or \npermanent establishments are not considered revenue of the \nrecipient-owner.\nRevenue also does not include imputed earnings or \ndeemed dividends from other constituent entities in your \ngroup that are taken into account solely for tax purposes and \nthat otherwise would be included as revenue by a constituent \nentity.\nFor a constituent entity that is an exempt organization, \nrevenue means only revenue that is reflected in unrelated \nbusiness taxable income. See Regulations section \n1.6038-4(d)(3)(ii).\nLine 2. Enter the aggregate profit or loss before income tax \nof the constituent entities listed in Part II.\nConsistent with the definition of revenue, profit or loss \nbefore income tax does not include payments received from \nother constituent entities in your group that are treated as \ndividends in the payor's tax jurisdiction.\nNote. An amount representing all or part of a constituent \nentity's profit that is required or permitted for financial \nreporting purposes to be included in the profit before tax of \nanother constituent entity in the group should be treated in \nthe same way as dividends from other constituent entities \nand excluded from revenue and profit or loss before income \ntax. This instruction does not apply where a constituent entity \nincludes in profit before tax for financial reporting purposes \nan amount representing all or part of the profit of another \nconstituent entity in the group that is fiscally transparent.\nLine 3. Enter the aggregate amount of income tax paid on a \ncash basis to all tax jurisdictions by the constituent entities \nlisted in Part II and any taxes withheld on payments received \nby the constituent entities listed in Part II.\nTaxes paid should include taxes paid in cash by a \nconstituent entity listed in Part II to its tax jurisdiction and to \nCAUTION\n!\nall other tax jurisdictions. Taxes paid should include \nwithholding taxes paid by other entities (whether related or \nunrelated) with respect to payments to the constituent \nentities in Part II.\nExample. If, during a reporting period, Company X \n(resident in tax jurisdiction X) generates operating income in \ntax jurisdiction X that is subject to corporate income tax in tax \njurisdiction X and earns interest income from a company in \ntax jurisdiction Y subject to withholding tax in tax jurisdiction \nY, the taxes paid to tax jurisdiction X on the operating income \nand the tax withheld on the interest and paid to tax \njurisdiction Y should be reported as part of the income taxes \npaid by Company X on the Schedule A (Form 8975) for tax \njurisdiction X.\nLine 4. Enter the aggregate of the total accrued current \nincome tax expense recorded on taxable profits or losses, \nreflecting only operations in the relevant annual period and \nexcluding deferred taxes or provisions for uncertain tax \nliabilities, for the constituent entities listed in Part II.\nWhen a constituent entity listed in Part II is a permanent \nestablishment, the amounts on line 3 and line 4 should not \ninclude the income tax paid or current income tax expense \naccrued by the business entity of which the permanent \nestablishment would otherwise be a part in that business \nentity’s tax jurisdiction of residence on the income derived by \nthe permanent establishment. For example, if Company X \n(resident in tax jurisdiction X) has a permanent establishment \n“PE Y” in tax jurisdiction Y that is considered a constituent \nentity, and Company X pays tax jurisdiction X income tax on \nincome earned by PE Y, then that income tax paid should be \nreflected on the Schedule A (Form 8975) for tax jurisdiction \nX. However, income tax paid to tax jurisdiction Y on income \nearned by PE Y is not included on the Schedule A (Form \n8975) for tax jurisdiction X, but rather on the Schedule A \n(Form 8975) for tax jurisdiction Y.\nLine 5. Enter the aggregate amount of the stated capital of \nthe constituent entities listed in Part II.\nThe stated capital of a permanent establishment must be \nreported in the tax jurisdiction of residence of the legal entity \nof which it is a permanent establishment unless there is a \ndefined capital requirement in the permanent establishment \ntax jurisdiction for regulatory purposes.\nLine 6. Enter the aggregate of total accumulated earnings of \nthe constituent entities listed in Part II. However, the \naccumulated earnings of a permanent establishment are \nconsidered those of the legal entity of which it is a permanent \nestablishment and should be reported on the Schedule A \n(Form 8975) for the tax jurisdiction of the legal entity owner.\nLine 7. Enter the aggregate number of employees on a \nfull-time equivalent basis of the constituent entities listed in \nPart II. The number of employees may be reported as of the \nyear-end, on the basis of average employment levels for the \nyear, or on any other basis consistently applied across tax \njurisdictions of your group and from year to year.\nReasonable rounding or approximation of the number of \nemployees is permissible, provided that such rounding or \napproximation does not materially distort the relative \ndistribution of employees across the various tax jurisdictions \nof your group. Consistent approaches should be applied from \nyear to year and across entities.\nLine 8. Enter the aggregate of the net book value of tangible \nassets of all the constituent entities listed in Part II. For \nInstructions for Form 8975 (Rev.12-2020)\n-5-\n", "purposes of this schedule, tangible assets do not include \ncash or cash equivalents, intangibles, or financial assets.\nFor permanent establishments, assets should be reported \non the Schedule A (Form 8975) for the tax jurisdiction in \nwhich the permanent establishment is located.\nPart II—Constituent Entity \nInformation\nIn this section, you will provide constituent entity information \nfor your group regarding the constituent entities that have the \ntax jurisdiction indicated in Part I. You should complete a row \nfor each constituent entity providing the information indicated \nbelow.\nLine 1. Enter the full legal name of the constituent entity, \nincluding the domestic designation for the legal form, as \nindicated in its articles of incorporation or any similar \ndocument. If the constituent entity is a permanent \nestablishment, the naming convention to use is the name of \nthe constituent entity of which the permanent establishment \nwould be a part (if it were not its own constituent entity), \nfollowed by “- (PE).” For instance, if XYZ Corp has a \npermanent establishment, that permanent establishment’s \nname would be “XYZ Corp - (PE).”\nIf filing electronically, the address of the constituent entity \nmay also be provided.\nLine 2. Enter the entity role used by the constituent entity as \none of the following values.\n• CBC801 Ultimate Parent Entity\n• CBC802 Reporting Entity\n• CBC803 Both (Ultimate Parent Entity and Reporting Entity)\nIf the roles above do not apply to the constituent entity role, \nleave blank.\nLine 3. Enter the tax identification number (TIN), if any, used \nfor the constituent entity by the tax administration in the tax \njurisdiction of residence. The TIN is a mandatory field and \nmust be entered for each constituent entity. If the constituent \nentity does not have a TIN, then enter “NOTIN.”\nIf filing electronically, one or more entity identification \nnumbers (IN), such as a company registration number, can \nbe provided, along with the IN’s issuer country and type.\nLine 4. Using the two-letter code from the list at IRS.gov/\nCountryCodes, enter the tax jurisdiction in which the \nconstituent entity is organized or incorporated if different from \nthe tax jurisdiction of residence. However, see Tax \njurisdiction under Part I—Tax Jurisdiction Information, earlier, \nfor codes that are not allowed.\nLine 5a. Identify the nature of the main business activity of \nthe constituent entity in the relevant tax jurisdiction by \nselecting at least one of the following codes or categories.\n• CBC501 Research and development\n• CBC502 Holding or managing intellectual property\n• CBC503 Purchasing or procurement\n• CBC504 Manufacturing or production\n• CBC505 Sales, marketing, or distribution\n• CBC506 Administrative, management, or support services\n• CBC507 Provision of services to unrelated parties\n• CBC508 Internal group finance\n• CBC509 Regulated financial services\n• CBC510 Insurance\n• CBC511 Holding shares or other equity instruments\n• CBC512 Dormant\n• CBC513 Other\nThose that do not file electronically are limited to indicating \na maximum of three main business activities. However, if you \nfeel this does not properly reflect the main businesses of a \nconstituent entity, you may use Part III, Additional \nInformation, on the appropriate Schedule A (Form 8975) to \nenter additional codes and explain.\nLine 5b. If you entered the code for “Other” on line 4a, \ndescribe the “Other” business activity.\nPart III—Additional Information\nBriefly describe the sources of data used in preparing Parts I \nand II of the Schedule A (Form 8975). The description should \nbe sufficient to enable an understanding of the source of \neach item of information supplied on the Schedule A (Form \n8975). The source(s) of data could include consolidation \nreporting packages, separate entity financial statements, \nregulatory financial statements, tax reporting records, or \ninternal management accounts reports. If a change is made \nto the source of data used from year to year, explain the \nreasons for the change and its consequences.\nAdditionally, you can enter any relevant information or \nexplanation that you deem necessary or that would facilitate \nthe understanding of the information provided in Parts I and \nII. The information may or may not relate to a specific \nconstituent entity. The information may be used to explain \nthe tax jurisdiction financial and employee information in Part \nI. You can use the item reference codes listed next to \nindicate if the additional information relates to a specific item \nin Part I.\n• CBC601 Revenues—unrelated party\n• CBC602 Revenues—related party\n• CBC603 Revenues—total\n• CBC604 Profit or loss\n• CBC605 Income tax paid\n• CBC606 Income tax accrued\n• CBC607 Stated capital\n• CBC608 Accumulated earnings\n• CBC609 Number of employees\n• CBC610 Tangible assets\nPaperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the \nUnited States. You are required to give us the information. We need it to ensure that you are complying with these laws and to \nallow us to figure and collect the right amount of tax.\nYou are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless \nthe form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long \nas their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return \ninformation are confidential, as required by section 6103.\nThe time needed to complete and file this form and related schedules will vary depending on individual circumstances. The \nestimated burden for taxpayers filing this form is approved under OMB control number 1545-2272. The estimated burden for all \nother taxpayers who file this form is shown below.\n-6-\nInstructions for Form 8975 (Rev.12-2020)\n", "Form 8975 and Schedule A (Form 8975) \n. . . . . . . . . . . . . . . . . . . .\n1hr., 30 min.\nIf you have comments concerning the accuracy of these time estimates or suggestions for making this form and related \nschedule simpler, we would be happy to hear from you. See the instructions for the tax return with which this form is filed.\nInstructions for Form 8975 (Rev.12-2020)\n-7-\n" ]
f8975sa.pdf	1220 Form 8975 (Schedule A) (PDF)	https://www.irs.gov/pub/irs-pdf/f8975sa.pdf	[ "SCHEDULE A \n(Form 8975)\n(Rev. December 2020)\nTax Jurisdiction and Constituent Entity Information\nDepartment of the Treasury \nInternal Revenue Service \n▶ A separate Schedule A (Form 8975) is to be completed for each tax jurisdiction of the multinational enterprise group. \n▶ Go to www.irs.gov/Form8975 for instructions and the latest information.\nOMB No. 1545-2272\nFor reporting period beginning\n, 20\n, and ending\n, 20\nName of the reporting entity\nEIN\nPart I\nTax Jurisdiction Information. All financial amounts must be stated in U.S. dollars. See instructions.\nTax jurisdiction\n1. Revenues\n2. Profit (loss) before \nincome tax\n3. Income tax paid \n(on cash basis)\n4. Income tax \naccrued—current \nyear\n5. Stated capital\n6. Accumulated \nearnings\n7. Number of \nemployees\n8. Tangible assets \nother than cash and \ncash equivalents\n(a) \nUnrelated party\n(b) \nRelated party\n(c) \nTotal\n \n \n \n \n \n \n \nPart II\nConstituent Entity Information \n1. Constituent entities resident in \nthe tax jurisdiction\n2. Entity \nrole\n3. TIN\n4. Tax jurisdiction of \norganization or \nincorporation if \ndifferent from tax \njurisdiction of \nresidence\n5. Main business activities\n(a) \nActivity code\n \n \n \n \n \n \n \n(b) \nIf you entered the code for “Other,” describe the \nbusiness activity.\nFor Paperwork Reduction Act Notice, see separate instructions.\nCat. No. 69310N\nSchedule A (Form 8975) (Rev. 12-2020)\n", "Schedule A (Form 8975) (Rev. 12-2020)\nPage 2\nPart II\nConstituent Entity Information (continued)\n1. Constituent entities resident in \nthe tax jurisdiction\n2. Entity \nrole\n3. TIN\n4. Tax jurisdiction of \norganization or \nincorporation if \ndifferent from tax \njurisdiction of \nresidence\n5. Main business activities\n(a) \nActivity code\n \n \n \n \n \n \n \n(b) \nIf you entered the code for “Other,” describe the \nbusiness activity.\nPart III\nAdditional Information\nEnter any additional information related to the information reported in Part I and II.\nSchedule A (Form 8975) (Rev. 12-2020)\n" ]
i5310a.pdf	1220 Inst 5310-A (PDF)	https://www.irs.gov/pub/irs-pdf/i5310a.pdf	[ "Instructions for\nForm 5310-A\n(Rev. December 2020)\nNotice of Plan Merger or Consolidation, Spinoff, or Transfer of Plan Assets or \nLiabilities; Notice of Qualified Separate Lines of Business\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue \nCode unless otherwise noted.\nFuture Developments\nFor the latest information about \ndevelopments related to Form 5310–A \nand it’s instructions, such as legislation \nenacted after they were published, go to \nwww.IRS.gov/forms5310.\nGeneral Instructions\nPurpose of Form\nForm 5310-A is used by employers to \ngive notice of:\n• A plan merger or consolidation that is \nthe combining of two or more plans into \na single plan.\n• A plan spinoff that is the splitting of a \nsingle plan into two or more spinoff \nplans.\n• A plan transfer of plan assets or \nliabilities to another plan that is the \nsplitting off of a portion of the assets or \nliabilities of the transferor plan and the \nconcurrent acquisition or assumption of \nthese split-off assets or liabilities by the \ntransferee plan.\n• Qualified separate lines of business \n(QSLOBs).\nNote. An IRS determination letter will \nnot be issued when a Form 5310-A is \nfiled.\nWho Must File\n• Pension plan, profit-sharing plan, \nor other deferred compensation \nplan. Any sponsor or plan administrator \nof a pension, profit-sharing, or other \ndeferred compensation plan (except a \nmulti-employer plan covered by Public \nBenefit Guaranty Corporation (PBGC) \ninsurance) should file this form for a \nplan merger or consolidation, a spinoff, \nor a transfer of plan assets or liabilities \nto another plan. See section 6058(b).\nNote. This form must be filed for each \nplan with a separate employer \nidentification and plan number if that \nplan is involved in a merger or transfer \nof plan assets or liabilities. This includes \nplans that were not in existence before \nthe plan merger and plans that cease to \nexist after the plan merger. In the case \nof a plan spinoff, file Form 5310-A only \nfor the plan in existence before the \nspinoff.\n• Qualified separate lines of \nbusiness. The employer must file \nnotice that it elects to be treated as \noperating QSLOBs or that it either \nmodifies or revokes a previously filed \nnotice. Only one notice per employer, \nwithin the meaning of sections 414(b), \n(c), and (m) is required.\nExamples\nExample One - Initial Notice\nEmployer A is composed of four \nseparate corporations that are treated \nas one employer within the meaning of \nsection 414(b). Employer A treats each \ncorporation as a separate line of \nbusiness. The 2018 testing year is the \nfirst year for which Employer A elects to \nbe treated as operating QSLOBs for the \npurpose of section 410(b) (see When \nTo File for a definition of “testing year”). \nEmployer A must file Form 5310-A and \nprovide information on each of the four \nQSLOBs on or before the notification \ndate for the 2018 testing year (see \nWhen To File for a definition of \n“notification date”). If the notice is not \ntimely filed, Employer A is not treated as \noperating QSLOBs for purposes of the \ncoverage rules for the 2018 testing year \n(see Part III ).\nExample Two - Modification\nThe facts are the same as in Example \nOne. During the 2019 testing year, \nEmployer A sold QSLOB four. Also, \nassume that Employer A timely filed \nForm 5310-A for the 2018 testing year. \nFor the 2019 testing year, Employer A \nintends to treat QSLOBs one and two as \na single QSLOB. Employer A must \nmodify its initial notice by filing Form \n5310-A on or before the notification date \nfor the 2019 testing year, including a \nrevised list of QSLOBs for line 11 of the \nform. If Employer A does not timely \nprovide a new notice, the initial notice \nfiled for the 2018 testing year will be \ntreated as the only notice filed for the \n2019 testing year (see Part III).\nExample Three - Revocation\nThe facts are the same as in Example \nTwo. Assume that Employer A timely \nfiled a new notice for the 2019 testing \nyear. During 2020, Employer A elects \nnot to treat itself as operating QSLOBs \nfor the 2020 testing year. Employer A \nmust revoke the last notice it filed (that \nis, the notice for the 2019 testing year). \nEmployer A must revoke the notice filed \nfor the 2019 testing year by filing Form \n5310-A for the 2020 testing year and \nindicating on line 9 of the Form 5310-A \nthat it is revoking a previously filed \nnotice and is no longer testing on a \nQSLOB basis. If such notice is not filed \non or before the notification date for the \n2020 testing year, the notice filed for the \n2019 testing year will be treated as the \nonly notice filed for the 2020 testing \nyear (see Part III).\nExceptions From Filing \nNotice of Plan Merger or \nConsolidation, Spinoff, or \nTransfer of Plan Assets or \nLiabilities\nDirect rollover. Do not file Form \n5310-A for an eligible rollover \ndistribution that is paid directly to an \neligible retirement plan in a direct \nrollover as described in section 401(a)\n(31).\nPlan merger or consolidation or \nspinoff. Do not file Form 5310-A if the \nplan merger or consolidation or the \nspinoff complies with Regulations \nsection 1.414(l)-1(d), (h), (m), or (n)(2).\nGenerally, these requirements will be \nsatisfied in the following four situations:\n1. Two or more defined contribution \nplans are merged and all of the \nfollowing conditions are met:\na. The sum of the account balances \nin each plan prior to the merger \n(including unallocated forfeitures, an \nunallocated suspense account for \nexcess annual additions, and an \nOct 19, 2020\nCat. No. 12899J\n", "unallocated suspense account for an \nESOP) equals the fair market value of \nthe entire plan assets.\nExample. Neither plan has an \noutstanding section 412(d) waiver \nbalance.\nb. The assets of each plan are \ncombined to form the assets of the plan \nas merged.\nc. Immediately after the merger, \neach participant in the plan has an \naccount balance equal to the sum of the \naccount balances the participant had in \nthe plans immediately prior to the \nmerger.\n2. There is a spinoff of a defined \ncontribution plan and all of the following \nconditions are met:\na. The sum of the account balances \nin the plan prior to the spinoff equals the \nfair market value of the entire plan \nassets.\nExample. The plan does not have an \noutstanding section 412(d) waiver \nbalance.\nb. The sum of the account balances \nfor each of the participants in the \nresulting plan(s) equals the account \nbalances of the participants in the plan \nbefore the spinoff.\nc. The assets in each of the plans \nimmediately after the spinoff equal the \nsum of the account balances for all \nparticipants in that plan.\nExample. The plan does not have \nunallocated accounts.\n3. Two or more defined benefit \nplans are merged into one defined \nbenefit plan and both of the following \nconditions are met:\na. The total liabilities (the present \nvalue of benefits whether or not vested) \nthat are merged into the larger plan \ninvolved in the merger are less than 3% \nof the assets of the larger plan. This \ncondition must be satisfied on at least 1 \nday in the larger plan's plan year during \nwhich the merger occurs. All previous \nmergers (including transfers from \nanother plan) occurring in the same plan \nyear are taken into account in \ndetermining the percentage of assets \ndescribed above.\nExample. Assume that a merger \ninvolving almost 3% of the assets of the \nlarger plan occurs in the first month of \nthe larger plan's plan year. In the fourth \nmonth of the larger plan's plan year, a \nsecond merger occurs involving \nliabilities equal to 2% of the assets of \nthe larger plan. The total of both \nmergers exceeds 3% of the assets of \nthe larger plan. As a result of the second \nmerger, both mergers must be reported \non Form 5310-A. Enter the date of the \nsecond merger on line 6g.\nAlso, mergers occurring in previous \nplan years are taken into account in \ndetermining the percentage of assets \nabove if the series of mergers is, in \nsubstance, one transaction with the \nmerger occurring during the current plan \nyear.\nAggregating mergers may cause a \nmerger, for which a Form 5310-A was \nnot initially required to be filed, to \nbecome reportable as a result of a \nsubsequent merger. In this case, the \nmerger(s) must be reported on the Form \n5310-A filed for the subsequent merger.\nb. The provisions of the larger plan \nthat allocate assets at the time of \ntermination must provide that, in the \nevent of a spinoff or termination of the \nplan within 5 years following the merger, \nplan assets will be allocated first for the \nbenefit of the participants in the other \nplan(s) to the extent of their benefits on \na termination basis just prior to the \nmerger.\n4. There is a spinoff of a defined \nbenefit plan into two or more defined \nbenefit plans and both of the following \nconditions are met:\na. For each plan that results from \nthe spinoff, other than the spunoff plan \nwith the greatest value of plan assets \nafter the spinoff, the value of the assets \nspun off is not less than the present \nvalue of the benefits spun off (whether \nor not vested).\nb. The value of the assets spun off \nto all the resulting spunoff plans (other \nthan the spunoff plan with the greatest \nvalue of plan assets after the spinoff) \nplus other assets previously spun off \n(including transfers to another plan) \nduring the plan year in which the spinoff \noccurs is less than 3% of the assets of \nthe plan before the spinoff as of at least \n1 day in that plan's plan year.\nExample. Assume that a spinoff \ninvolving almost 3% of the assets of the \nplan occurs in the first month of the plan \nyear. In the fourth month of the plan \nyear a second spinoff occurs involving \nliabilities equal to 2% of the assets of \nthe plan. The total of both spinoffs \nexceeds 3% of the plan assets. As a \nresult of the second spinoff, Form \n5310-A must be filed to report both \nspinoffs. Enter the date of the second \nspinoff on line 6g.\nSpinoffs occurring in previous or \nsubsequent plan years are taken into \naccount in determining the percentage \nof assets spun off if such spinoffs are, in \nsubstance, one transaction with the \nspinoff occurring during the current plan \nyear.\nAggregating spinoffs may cause a \nspinoff, for which a Form 5310-A was \nnot initially required to be filed, to \nbecome reportable as a result of a \nsubsequent spinoff. In this case, report \nthe spinoff(s) on the Form 5310-A filed \nfor the subsequent spinoff. Enter the \ndate of the subsequent spinoff on \nline 6g.\nTransfer of Plan Assets or Liabilities. \nA transfer of plan assets or liabilities is \nconsidered a combination of separate \nplan spinoffs and mergers.\nDo not file Form 5310-A for:\n• The transferor plan in a transfer \ntransaction if the assets transferred \nsatisfy the spinoff conditions in 2 or 4 \nabove.\n• The transferee plan in a transfer \ntransaction if the plan liabilities \ntransferred satisfy the merger conditions \nin 1 or 3 above.\nNote. In some situations, the transferor \nplan may have to file Form 5310-A but \nnot the transferee plan, or the transferee \nplan may have to file but not the \ntransferor plan.\nExamples\nTransfer of Plan Assets or \nLiabilities\nPlans A, B, and C are separate plans \nwithin the meaning of section 414(l). A \nportion of the assets and liabilities of \nboth Plan B and Plan C will be \ntransferred to Plan A. None of the plans \nare excluded from filing under the \nexceptions from filing listed above. In \nthis situation all 3 plans must:\n• File a completed Form 5310-A.\n• Enter code 4 (notice of a transfer of \nplan assets or liabilities) as the reason \nfor filing.\n• Complete all parts of Part I and II of \nthe form.\nFor Plan A, line 6 of the form will show \ninformation regarding Plan B and an \nattached statement with the line 6 \ninformation for Plan C. Plan B and Plan \nC will each enter the information \nregarding Plan A on line 6.\nPlan Merger\nPlans A, B, and C are separate plans \nwithin the meaning of section 414(l). \nPlans A, B, and C are being merged. \nAssets and liabilities from each plan will \nbe merged into Plan D, a new plan that \nwas established for the purpose of \neffecting the merger. None of the plans \n-2-\n", "are excluded from filing under the \nexceptions from filing above.\nIn this situation, four separate Forms \n5310-A must be filed. Because Plan D is \nreceiving assets from Plans A, B, and C, \nPlan D must file a complete Form \n5310-A, enter code 2 (notice of a plan \nmerger) as the reason for filing, and \ncomplete all of Parts I and II of the form. \nLine 6 of the form will show information \nregarding Plan A and an attached \nstatement with the line 6 information for \nPlans B and C. Plans A, B, and C are \nmerging with Plan D. Plans A, B, and C \nwill each file a separate Form 5310-A \ncompleted as follows: Enter code 2 as \nthe reason for filing, complete all of \nParts I and II, and enter the information \nregarding Plan D on line 6.\nWhen To File\n• File Form 5310-A at least 30 days \nprior to a plan merger or consolidation, \nspinoff, or transfer of plan assets or \nliabilities to another plan.\n• If you are filing Form 5310-A to notify \nthe IRS that the employer treats itself as \noperating QSLOBs or the employer is \nmodifying or revoking a previously filed \nnotice, file Form 5310-A on or before the \nnotification date for the testing year. The \n“notification date” for a testing year is \nthe later of: (a) October 15 of the year \nfollowing the testing year, or (b) the 15th \nday of the 10th month after the close of \nthe plan year of the plan of the employer \nthat begins earliest in the testing year. \n“Testing year” means the calendar year.\nPenalties\nThere is a penalty for the late filing of a \nForm 5310-A to report a plan merger or \nconsolidation, spinoff, or transfer of plan \nassets or liabilities. The penalty is $250 \na day for each day the Form 5310-A is \nlate (up to a maximum of $150,000). \nThe form is late if it is not filed at least \n30 days before the plan merger or \nconsolidation, spinoff, or transfer of plan \nassets or liabilities.\nWhere To File\nFile Form 5310-A at the address \nindicated below:\nInternal Revenue Service\nTE/GE Stop 31A Team 105\nP.O. Box 12192\nCovington, KY 41012-0192\nRequests shipped by Express Mail or \na delivery service should be sent to:\nInternal Revenue Service\n7940 Kentucky Drive\nFlorence, KY 41042\nPrivate delivery services. In addition \nto the United States mail, you can use \ncertain private delivery services \ndesignated by the IRS to meet the \n“timely mailing as timely filing/paying” \nrule for tax returns and payments. \nThese private delivery services include \nonly the following.\n• DHL Express (DHL): DHL Same Day \nService.\n• Federal Express (FedEx): FedEx \nPriority Overnight, FedEx Standard \nOvernight, FedEx 2Day, FedEx \nInternational Priority, and FedEx \nInternational First.\n• United Parcel Service (UPS): UPS \nNext Day Air, UPS Next Day Air Saver, \nUPS 2nd Day Air, UPS 2nd Day Air \nA.M., UPS Worldwide Express Plus, \nand UPS Worldwide Express.\nThe private delivery service can tell \nyou how to get written proof of the \nmailing date.\nSignature\nStamped signatures are not \nacceptable; see Rev. Proc. \n2020-4, which is on page 251 of \nInternal Revenue Bulletin 2020-1 at \nwww.irs.gov/pub/irs-irbs/irb20-01.pdf.\nIn general, the employer or plan \nadministrator must sign the form. For \nsingle employer plans the plan \nadministrator and the employer are \ngenerally the same person. When the \nplan administrator is a joint employer —\nunion board or committee — at least \none employer representative and one \nunion representative must sign. A Form \n5310-A filed with the IRS by a \nrepresentative on behalf of an employer \nor plan administrator must be \naccompanied by:\n1. A power of attorney specifically \nauthorizing such representation in this \nmatter (you may use Form 2848, Power \nof Attorney and Declaration of \nRepresentative), or\n2. A written declaration that the \nrepresentative is a currently qualified \nattorney, certified public accountant, \nenrolled actuary, or is currently enrolled \nto practice before the IRS (include either \nthe enrollment number or the expiration \ndate of the enrollment card) and is \nauthorized to represent the employer or \nplan administrator.\nCAUTION\n!\nHow To Complete the \nNotice\nForm 5310-A is screened for \ncompleteness. Incomplete notices will \nbe returned. Here are some tips to help \nyou complete the form correctly.\n1. The notice has formatted fields \nthat will limit the number of characters \nentered per field.\n2. All data input will need to be \nentered in Courier size 10 font.\n3. Alpha characters should be \nentered in all capital letters.\n4. Enter spaces between any \nwords. Spaces will count as a character.\n5. All data fields are entered as an 8 \ndigit field in MMDDYYYY format.\n6. If a number is requested, a \nnumber must be entered.\n7. For questions regarding this form, \ncall the Employee Plans Customer \nService at 1-877-829-5500.\nThe IRS may, at its discretion, \nrequire additional information or the \nsubmission of a Form 5300, Application \nfor Determination for Employee Benefit \nPlan, when it is deemed necessary.\nSpecific Instructions\nLine 1 — Reason for filing. Enter the \nappropriate code that describes the \nreason you are filing Form 5310-A.\nEnter 1 for a notice of qualified \nseparate lines of business.\nEnter 2 for a notice of a plan merger \nor consolidation.\nEnter 3 for a notice of a plan spinoff.\nEnter 4 for a notice of a transfer of \nplan assets or liabilities to another plan.\nPart I — All Filers Must \nComplete Part I\nLines 2a and 2b. Enter the name and \naddress of the employer or plan \nsponsor. A plan sponsor means:\n1. In the case of a plan that covers \nthe employees of one employer, the \nemployer;\n2. In the case of a plan sponsored \nby two or more entities required to be \naggregated under sections 414(b), (c), \nor (m), one of the members participating \nin the plan; or\n3. In the case of a plan that covers \nthe employees and/or partners of a \npartnership, the partnership.\nThe name of the plan sponsor/\nemployer should be the same name that \nwas or will be used when the Form \n-3-\n", "5500, Annual Return/Report of \nEmployee Benefit Plan, series returns/\nreports are filed for the plan.\nAddress. Include the suite, room, or \nother unit number after the street \naddress. If the Post Office does not \ndeliver mail to the street address and \nthe plan has a P.O. box, show the box \nnumber instead of the street address. \nThis address should be the address of \nthe sponsor/employer.\nLine 2g. Enter the 9-digit employer \nidentification number (EIN) assigned to \nthe plan sponsor/employer. This should \nbe the same EIN that was or will be \nused when the Form 5500 series annual \nreturns/reports are filed for the plan. For \na multiple employer plan, the EIN \nshould be the same EIN that was or will \nbe used when Form 5500 is filed.\nDo not use a social security \nnumber or the EIN of the trust.\nThe plan sponsor/employer must \nhave an EIN. A plan sponsor/employer \nwithout an EIN can apply for one.\n• Online—Generally, a plan sponsor/\nemployer can receive an EIN by Internet \nand use it immediately to file a return. \nGo to the IRS website at www.irs.gov/\nbusinesses/small and click on Employer \nID Numbers.\n• By telephone—Call 1-800-829-4933.\n• By mail or fax—Send in a completed \nForm SS-4, Application for Employer \nIdentification Number, to apply for an \nEIN.\nNote. Form SS-4 can be obtained at \nSocial Security Administration (SSA) \noffices or by calling 1-800-TAX-FORM.\nFor the plan of a group of entities \nrequired to be combined under sections \n414(b), (c), or (m), whose sponsor is \nmore than one of the entities required to \nbe combined, enter the EIN of only one \nof the sponsoring members. This EIN \nmust be used in all subsequent filings of \ndetermination letter requests, and for \nfiling annual returns/reports unless there \nis a change of sponsor.\nLine 3. The contact person will receive \ncopies of all correspondence as \nauthorized in a Form 2848, or Tax \nInformation Authorization, Form 8821. \nEither complete the contact's \ninformation on this line, or check the box \nand attach a completed Form 2848 or \nForm 8821.\nCAUTION\n!\nPart II—Plan Merger, \nConsolidation, Spinoff, or \nTransfer\nLine 4a. Enter the name you \ndesignated for your plan. Due to space \nrestrictions, this field is limited to 70 \ncharacters, including spaces. Due to \nthis restriction, “Employee” and “Trust” \nare not necessary in the plan name.\nLine 4b. Enter the 3-digit number, \nbeginning with “001” and continuing in \nnumerical order for each plan you adopt \n(001–499). The number assigned to a \nplan must not be changed or used for \nany other plan. This should be the same \nnumber that was or will be used when \nthe Form 5500 series returns/reports \nare filed for the plan.\nLines 5a. Attach an actuarial statement \nof valuation showing compliance with \nsection 414(l). The statement must (1) \nidentify the type of transaction involved \n(for example, merger or consolidation, \nspinoff, or transfer of plan assets or \nliabilities), and (2) provide information \nverifying compliance with the \nrequirements of sections 401(a)(12) and \n414(l). This statement need not be \nsigned by an actuary.\nLine 5b. Enter the code that describes \nyour plan.\nEnter 1 for a profit-sharing plan.\nEnter 2 for a stock bonus plan.\nEnter 3 for a money purchase plan.\nEnter 4 for a target benefit plan.\nEnter 5 for a profit-sharing/401(k) \nplan.\nEnter 6 for an ESOP plan.\nEnter 7 for other and specify the type \nof plan.\nLine 6a. Enter the total number of \nplans, other than the plan named on \nline 4a, involved in this transaction.\nLines 6c through 6h. Complete lines \n6c through 6h for the other plan(s) \ninvolved in the merger or consolidation, \nspinoff, or transfer of plan assets or \nliabilities with the plan named on line 4a. \nIf there is more than one other plan, \nattach a separate statement showing \nthe information requested for lines 6c \nthrough 6h.\nExample: Plans A, B, and C are \nmerging with Plan D. Plan D would \ncomplete a Form 5310-A, reporting \ninformation about itself on line 4. Plan D \nwould then complete the line 6 \ninformation for Plan A and attach two \nstatements showing the line 6 \ninformation for Plans B and C. In \naddition, Plans A, B, and C must each \nfile a separate Form 5310-A (see the \nexample of a plan merger).\nLine 6h. Enter the code that describes \nthe other plan.\nEnter 1 for a defined benefit plan.\nEnter 2 for a profit-sharing plan.\nEnter 3 for a profit-sharing/401(k) \nplan.\nEnter 4 for a stock bonus plan.\nEnter 5 for an ESOP plan.\nEnter 6 for a money purchase plan.\nEnter 7 for a target benefit plan.\nPart III—Qualified \nSeparate Lines of \nBusiness\nRev. Proc. 93-40, 1993-2 C.B. 535, \ncontains procedures relating to the \nnotification requirements of section \n414(r)(2)(B).\nNotice given by an employer applies \nto all plans maintained by the employer \nfor plan years beginning in the testing \nyear. Once the notification date (see \nWhen To File) for a testing year has \npassed, the employer is deemed to \nhave irrevocably elected to apply the \nspecified section(s) on the basis of \nQSLOBs for all plan years beginning in \nthe testing year.\nIn addition, after the notification date, \nnotice cannot be modified, withdrawn, \nor revoked, and will be treated as \napplying to subsequent testing years \nunless the employer takes timely action \nto provide new notice (see examples \nunder Who Must File). Timely action will \nbe deemed to have been taken any time \nprior to the notification date for any \nsubsequent testing year.\nLine 7a. If you previously filed a notice \nof QSLOB for a testing year, enter the \nfirst testing year for which such notice \napplied on line 7b. Enter the date the \nnotice was filed on line 7c.\nLine 8. Enter the first testing year for \nwhich this notice applies. See When To \nFile for the definition of “testing year.”\nLine 9. Indicate whether you are filing \nthis form to give notice that you are no \nlonger testing on a QSLOB basis. If your \nanswer to line 9 is “Yes,” complete \nline 10 and skip lines 11 and 12. Answer \nline 10 based on the previously filed \nnotice that you are now revoking. If your \nanswer to line 9 is “No,” complete lines \n10 through 12. See Who Must File for \nan example of a revocation.\n-4-\n", "Line 10. Section 414(r) provides rules \nfor determining whether an employer \noperates QSLOBs for purposes of \napplying sections 410(b) (relating to \nminimum coverage), 401(a)(26) \n(relating to minimum participation rules), \nand 129(d)(8) (relating to dependent \ncare assistance programs). If you are \ntreated as operating QSLOBs under \nsection 414(r), you will be permitted to \napply the aforementioned Code \nprovisions separately for the employees \nin each QSLOB. Check the appropriate \nbox(es) for the section(s) you are testing \non a QSLOB basis. See instructions for \nline 9 to determine how to answer this \nquestion if you answered \"Yes\" to line 9.\nLine 11. Attach a list identifying the part \nor parts of the employer that make up \neach QSLOB of the employer. The list \nshould include, for example, the type of \nbusiness or industry in which the \nQSLOB is involved, the business unit \n(such as corporation, partnership, or \ndivision) the qualified line of business \ncomprises, and the name (formal or \ninformal) of the QSLOB.\nLine 12. Enter the information \nrequested on lines 12a through 12e. If \nthere is more than one plan, attach a \nseparate statement showing the \ninformation requested on lines 12a \nthrough 12e for each plan.\nLine 12b. Enter the date of the \ndetermination letter, if any. Otherwise, \nleave blank.\nLine 12c. If the plan is a master or \nprototype or volume submitter plan, \nenter the date of the letter and the serial \nnumber or the advisory letter number, \nas applicable.\nLine 12d. Enter the appropriate date of \nany pending letter request. If this \nquestion is not applicable, leave blank.\nLine 12e. List on this line the QSLOBs \nidentified on line 11 that have \nemployees benefiting under the plan. If \nyou need additional space to list the \nQSLOBs, use the area below line 12e.\nHow To Get Forms\nand Publications\nGetting tax forms, instructions, and \npublications. Visit IRS.gov/Forms to \ndownload current and prior-year forms, \ninstructions, and publications. Ordering \ntax forms, Instructions, and \npublications. Go to IRS.gov/Forms to \norder forms, instructions, and \npublications.\nPrivacy Act and Paperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue \nlaws of the United States. Our legal right to ask for this information is in sections 401, 403, 410, 411, 412, and 414 and their \nregulations. Section 6109 requires you to provide your identifying number. This form must be filed for any plan with a separate \nemployer identification and plan number if that plan is involved in a merger or transfer of plan assets or liabilities. Failure to \nprovide all of the information requested may prevent processing of this form. In addition, failing to file this form timely and in \naccordance with its instructions, or providing false information, may subject you to penalties. Routine uses of this information \ninclude giving it to the Department of Justice for civil and criminal litigation, and to cities, states, the District of Columbia, and \nU.S. commonwealths and possessions for administering their tax laws. We may also disclose this information to federal and \nstate agencies to enforce federal nontax criminal laws, or to federal law enforcement and intelligence agencies to combat \nterrorism.\nYou are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless \nthe form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long \nas their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return \ninformation are confidential, as required by section 6103.\nThe time needed to complete and file the form is listed below and will vary depending on individual circumstances. The \nestimated average time is:\nRecordkeeping\nLearning about the \nlaw or the form\nPreparing, copying, \nassembling, and sending the \nform to the IRS\nPart I\n2 hr., 9 min.\n1 hr., 3 min.\n2 hr., 20 min.\nPart II\n3 hr., 21 min.\n 35 min.\n 40 min.\nPart III\n4 hr., 32 min.\n 35 min.\n 42 min.\nIf you have comments concerning the accuracy of these time estimates or suggestions for making this form simpler, we \nwould be happy to hear from you. You can write to Internal Revenue Service, Tax Products Coordinating Committee, \nSE:W:CAR:MP:T:T:SP, 1111 Constitution Ave. NW, IR-6526, Washington, DC 20224.\nDo not send the form to this address. Instead, please see Where To File.\n-5-\n" ]
f8975.pdf	1220 Form 8975 (PDF)	https://www.irs.gov/pub/irs-pdf/f8975.pdf	[ "Form 8975\n(Rev. December 2020)\nDepartment of the Treasury \nInternal Revenue Service \nCountry-by-Country Report\n▶ Go to www.irs.gov/Form8975 for instructions and the latest information.\nOMB No. 1545-2272\nFor reporting period beginning\n, 20\n, and ending\n, 20\nIf this is an amended report, check here\nEnter the number of Schedules A (Form 8975) attached to this Form 8975 ▶ \nPart I\nIdentification of Filer\n1a Name of the reporting entity\n1b Reporting role code\n1c EIN\n2\nNumber, street, and room or suite no. (if P.O. box, see instructions)\n3a City or town\n3b State or province\n3c Country, and ZIP or foreign postal code\n4\nName of the U.S. Multinational Enterprise (MNE) group (if different from reporting entity)\nPart II\nAdditional Information\nEnter any additional information related to the U.S. MNE group\nFor Paperwork Reduction Act Notice, see separate instructions.\nCat. No. 37798N\nForm 8975 (Rev. 12-2020)\n", "Form 8975 (Rev. 12-2020)\nPage 2\nPart II\nAdditional Information (continued)\nForm 8975 (Rev. 12-2020)\n" ]
f945a.pdf	1220 Form 945-A (PDF)	https://www.irs.gov/pub/irs-pdf/f945a.pdf	[ "Form 945-A\n(Rev. December 2020)\nAnnual Record of Federal Tax Liability\nDepartment of the Treasury \nInternal Revenue Service\n▶ Go to www.irs.gov/Form945A for instructions and the latest information. \n▶ File with Form 945, 945-X, CT-1, CT-1 X, 944, or 944-X.\nOMB No. 1545-1430\nCalendar Year\nName (as shown on Form 945, 945-X, CT-1, CT-1 X, 944, or 944-X)\nEmployer identification number (EIN)\nYou must complete this form if you’re a semiweekly schedule depositor or became one because your accumulated tax liability during any month was \n$100,000 or more. Show tax liability here, not deposits. (The IRS gets deposit data from electronic funds transfers.) Don’t change your current year tax \nliability by adjustments reported on any Form 945-X, CT-1 X, or 944-X.\nJanuary Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nA \nTotal for month ▶\nFebruary Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\nB Total for month ▶\nMarch Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nC Total for month ▶\nApril Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\nD Total for month ▶\nMay Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nE Total for month ▶\nJune Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\nF Total for month ▶\nFor Paperwork Reduction Act Notice, see the separate instructions.\nCat. No. 14733M\nForm 945-A (Rev. 12-2020)\n", "Form 945-A (Rev. 12-2020)\nPage 2\nJuly Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nG Total for month ▶\nAugust Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nH Total for month ▶\nSeptember Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\nI \nTotal for month ▶\nOctober Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nJ \nTotal for month ▶\nNovember Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\nK Total for month ▶\nDecember Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nL Total for month ▶\nM Total tax liability for the year (add lines A through L). This must equal line 3 on Form 945 (line 19 \non Form CT-1, line 9 on Form 944). \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nForm 945-A (Rev. 12-2020)\n" ]
p5471.pdf	1120 Publ 5471 (PDF)	https://www.irs.gov/pub/irs-pdf/p5471.pdf	[ " \n \nPublication 5471 (11-2020) Catalog Number 75168J Department of the Treasury Internal Revenue Service www.irs.gov \n \n \n \nNovember 2020 \nDisclosure and Use of Tax \nInformation – Internal Revenue \nCode (IRC) 7216 Requirements \nfor VITA/TCE Partners \nThis document provides guidance for securing approval from the taxpayer to use or disclose \ninformation for purposes other than preparing and filing their tax returns. \nBackground: \nProtecting taxpayer information is critical to maintaining the strong integrity and success of the \nVITA/TCE programs. Final Treasury Regulations under IRC 7216, Disclosure or Use of Tax \nInformation by Preparers of Returns, became effective December 28, 2012. In general, the regulation \nrequires tax return preparers – including volunteer preparers – who intend to use or disclose a \ntaxpayer’s tax return information for a purpose other than current, prior and subsequent return \npreparation, to obtain taxpayer consent and provide taxpayers with specific information. This includes \nwho will receive their tax return information and the particular items of tax return information that will \nbe disclosed or used. \nIf a taxpayer’s consent is granted to share their tax return data, Federal Law may not protect the \ntaxpayer’s tax return information from further use or distribution. This means taxpayers must clearly \nunderstand how their information will be used before they agree to share it. Based on this, our partners \nare required to explain how taxpayers’ information will be shared and used. \nWhat are Consents? \nConsents are paper or electronic documents that contain specific information, including the names of \nthe tax return preparer and the taxpayer. They are customized to include the specific use or \ndisclosure. Consents are valid only if they are made by the taxpayer knowingly and voluntarily and are \nsigned and dated by the taxpayer in pen-and-ink (handwritten) or electronically. Consent forms must \ninclude certain language and warnings. Refer to Treas. Reg. §301.7216-3(a)(3) and Revenue \nProcedures 2013-14 and 2013-19 for complete information. \nWhen are Consents not Required? \nExceptions to required consents can be found in Treas. Reg. §301.7216-2. Some instances where \nconsents are not required include: \n■ \nDisclosures to the IRS \n■ \nDisclosures to other U.S. based tax return preparers that assist in preparing the return \n■ \nTo create lists for solicitation of tax return preparation business \n", "Fact Sheet: Disclosure and Use of Information – Internal Revenue Code (IRC) 7216 Requirements for VITA/TCE Partners \n2 \n■ \nTo produce certain limited statistical compilations in connection with tax return preparation business \nthat includes return counts, credit counts or refund counts (without dollar amounts) provided that it \ndoes not include any personally identifiable information or cells with data from fewer than ten tax \nreturns. \nNote: Statistical information with dollar amounts can be used for fundraising purposes without consent \nIn addition, a VITA/TCE site may compile and maintain a separate list containing names, mailing \naddresses, email addresses, phone numbers and taxpayer entity classification. \nVITA/TCE program coordinators can contact the taxpayers on the list for the purpose of providing \ninformation – such as tax information, general business information, economic information or analysis \nfor educational purposes – or to solicit additional tax return preparation services. \nNote: Safeguards should be taken to protect Personally Identifiable Information (PII) to reduce the \nlikelihood of identity theft and misuse of volunteer information. \nExample: Preparer A prepares federal and state income tax returns for taxpayers who live in \nPennsylvania, New Jersey, Maryland and Delaware. Preparer A maintains a list of taxpayer \nclients containing the information allowed. Preparer A provides quarterly state income tax \ninformation updates to individual taxpayer clients by email or U.S. mail. To ensure that clients \nonly receive the information updates that are relevant to them, Preparer A uses his list to direct \noutreach efforts towards the relevant clients by searching his list to filter it by zip code. Preparer A \nmay use the list information in this manner without taxpayer consent because he is providing tax \ninformation for educational or informational purposes. \nWhat is the Partner’s Responsibility? \nPartners should develop a script for volunteers to explain to taxpayers the specific information, \nincluding who will receive their tax return information and the tax return information that will be \ndisclosed or used. \nWhat are the Four Types of Consents? \n■ \nUse \n \n \n \n \n■ \nDisclosure \n■ \nGlobal Carryforward \n■ \nRelational EFIN \nConsent to Use: \nA consent to “use” allows the partner to roll-up the total dollar amounts associated with the refund \nissued and the qualified credits offered from all returns. This does not include personal information \nsuch as names, addresses, SSNs/ITINs, bank account information or other personal taxpayer data \nfrom the tax return. The consent must include the name and site address, the data used, the \nbusiness/partner using the information and purpose. \nExample A: A site wants to use tax return information to generate solicitations for products or \nservices other than tax return preparation, such as mortgages or Individual Retirement Accounts \n(IRAs). To determine whether this service may be of interest to a taxpayer, the partner or sub-\npartner will need to use some of the tax return data. If the taxpayer consents to the use, the \npartner can use their tax return information to determine whether this service will benefit them. \nExample B: A site wants to create marketing material to show their tax preparation service’s \nimpact on the community. If the taxpayer consents to the use, the partner can include their return \ninformation – including aggregate refund and credit dollar amounts – in their compiled data. \n", "Fact Sheet: Disclosure and Use of Information – Internal Revenue Code (IRC) 7216 Requirements for VITA/TCE Partners \n3 \nIf the taxpayer denies the consent, the partner cannot use their tax return information; however, the \ntaxpayer cannot be denied tax return preparation services. The return can be prepared and e-filed by \nthe site. \nConsent to Disclose: \nA consent to “disclose” allows the partner to disclose the taxpayer’s tax return information to determine \nwhether the taxpayer will benefit from services offered such as financial advisory and asset planning. \nExample: A site produced an anonymous statistical compilation of tax return information obtained \nduring the filing season. The next filing season the site wants to disclose portions of the \nanonymous statistical compilation from aggregated figures containing data from ten or more tax \nreturns in connection with the marketing of its financial advisory and asset-planning services. The \nsite is required to receive taxpayer consent before disclosing the tax return information contained \nin the anonymous statistical compilation because the disclosure is not being made in support of \nthe site’s tax return preparation business. \nIf the taxpayer denies the consent, the partner cannot disclose their tax return data; however, the \ntaxpayer cannot be denied tax preparation services. The return can be prepared and e-filed by the \nsite. \nConsent to Global Carry Forward: \nThis consent allows all tax returns prepared within one VITA/TCE site to be available to all VITA/TCE \npartners/sites. This means the taxpayer will be able to visit any volunteer site next year and have their \ntax return populate with current year data, regardless of where it was filed this year. \nThe tax return information that will be disclosed includes – but is not limited to – demographic, financial \nand other personally identifiable information about the taxpayer, their tax return and their sources of \nincome, which was input into the tax preparation software for the purpose of preparing their tax return. \nIf the taxpayer denies the consent, their data will not be available in sites other than where the last \nyear’s return was prepared. In addition, the taxpayer cannot be denied tax preparation services. The \nreturn can be prepared and e-filed by the site. \nConsents to Relational EFIN: \nThe relational EFIN process requires the tax preparation software provider to share the return data \nwith a third party, the primary sponsor. Since the taxpayer data is shared, taxpayers must consent to \n“disclose” the data before electronically filing a tax return. \nIf the taxpayer does not grant consent, or no PIN and date are entered at a VITA or non-Tax-Aide TCE \nsite, the e-file provider cannot disclose their data and the return cannot be e-filed because the \nrelational EFIN process shares the data with the preparing site and the primary sponsor when the \nreturn is acknowledged. The taxpayer cannot be denied tax preparation services. The software can be \nused to prepare the return; however, the return must be filed on paper (not e-filed). However, AARP \nTax-Aide sites can e-file the tax return. \nNote: Global Carryforward and Relational consents are pre-loaded by TaxSlayer and cannot be \nedited or deleted by the VITA/TCE site. Use and Disclose consents are added by the VITA/TCE site \nand may be edited or deleted by the site coordinator, if needed. \nMultiple Disclosures or Uses Within a Single Consent Form \nTreasury Regulations section 301.7216-3(c)(1) provides that a taxpayer may consent to multiple uses \nwithin the same written document or multiple disclosures within the same written document. Refer to \nPublication 4299 for additional guidance. \nElectronic Signature Requirements \n", "Fact Sheet: Disclosure and Use of Information – Internal Revenue Code (IRC) 7216 Requirements for VITA/TCE Partners \n4 \nRev. Proc. 2013-14 provides specific requirements for a taxpayer’s electronic signature to consent to \ndisclose or use taxpayer’s tax return information. Unless an exception is granted, all consents to \ndisclose or use tax return information must be physically signed by the taxpayer. A verbal consent is \nnot an affirmative action and therefore not acceptable as a valid consent. \nFor electronic consents, a tax return preparer must obtain a taxpayer’s signature on the consent by \none of the following methods. Consult your software provider to determine which method(s) is/are \navailable in your tax preparation software. Not all software providers support all methods. \n■ \nPreparers may assign a personal identification number (PIN) that is at least 5 characters long for the \ntaxpayer (such as their zip code) if the taxpayer signs a paper consent granting permission prior to \nentering the PIN. If not, the taxpayer may type in the pre-assigned PIN as the taxpayer’s signature \nauthorizing the disclosure or use. The taxpayer must physically enter the PIN for the electronic \nsignature to be valid. \n■ \nIf a paper consent granting permission in advance is not secured, have the taxpayer type in the \ntaxpayer’s name and then hit “enter” to authorize the consent. The taxpayer must physically type the \nname for the electronic consent to be valid. \n■ \nAny other manner in which the taxpayer physically enters 5 or more characters unique to the taxpayer \nthat the tax return preparer uses to verify the taxpayer’s identity. For example, entry of a response to \na question regarding a shared secret (such as mother’s maiden name, favorite color, significant date, \netc.) could be the type of information by which the taxpayer authorizes disclosure or use of tax return \ninformation. \nResources: \nPublication 4299, Privacy, Confidentiality and Civil Right - A Public Trust \nPublication 4396-A, Partner Resource Guide \nVisit the Section 7216 Information Center on irs.gov \nRev. Proc. 2013-14 \nTaxSlayer Pro Online User Guide - For detailed instructions on Working with Consents in TaxSlayer \n \nContact: If you have any questions, please contact your local SPEC relationship manager. \n \n \n" ]
f1120ssb.pdf	1220 Form 1120-S (Schedule B-1) (PDF)	https://www.irs.gov/pub/irs-pdf/f1120ssb.pdf	[ "SCHEDULE B-1 \n(Form 1120-S)\n(Rev. December 2020)\nInformation on Certain Shareholders of an S Corporation\nDepartment of the Treasury \nInternal Revenue Service \n▶ Attach to Form 1120-S.\n▶ Go to www.irs.gov/Form1120S for the latest information.\nOMB No. 1545-0123\nName of corporation\nEmployer identification number \nInformation on Any Shareholder That Was a Disregarded Entity, a Trust, an Estate, or a Nominee or Similar \nPerson at Any Time During the Tax Year (Form 1120-S, Schedule B, Question 3)\n(a) \nName of Shareholder of Record—Disregarded Entity, \nTrust, Estate, Nominee or Similar Person\n(b) \nSocial Security Number (SSN) \nor Employer Identification \nNumber (EIN) (if any) of \nShareholder of Record \n(c) \nType of Shareholder \n of Record\n(d) \nName and SSN or EIN (if any) of Individual or \nEntity Responsible for Reporting Shareholder’s \nIncome, Deductions, Credits, etc., From \nSchedule K-1\nFor Paperwork Reduction Act Notice, see the Instructions for Form 1120-S.\nCat. No. 60837X\nSchedule B-1 (Form 1120-S) (Rev. 12-2020)\n", "Schedule B-1 (Form 1120-S) (Rev. 12-2020)\nPage 2\nGeneral Instructions\nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nFor the latest information about developments related to \nSchedule B-1 (Form 1120-S) and its instructions, such as \nlegislation enacted after they were published, go to \nwww.irs.gov/Form1120S.\nPurpose of Form\nUse Schedule B-1 (Form 1120-S) to provide the information \napplicable to any shareholder in the S corporation that was a \ndisregarded entity, a trust, an estate, or a nominee or similar \nperson at any time during the tax year.\nIf the shareholder was a disregarded entity, provide the \ninformation even if the name, address, and social security \nnumber (SSN) or employer identification number (EIN) (if any) of \nthe owner of the disregarded entity was entered on Schedule \nK-1 (Form 1120-S), Shareholder’s Share of Income, Deductions, \nCredits, etc. If the shareholder was a nominee, guardian, \ncustodian, or agent, provide the information even if the name, \naddress, and SSN or EIN (if any) of the person for whom the \nstock was held was entered on Schedule K-1 (Form 1120-S).\nWho Must File\nSchedule B-1 (Form 1120-S) must be filed by all S corporations \nthat answer “Yes” to Form 1120-S, Schedule B, question 3. \nAttach Schedule B-1 to Form 1120-S.\nSpecific Instructions\nColumn (a)\nEnter the name of the shareholder (owner) of record in column \n(a). For example:\n• If a disregarded entity (for example, a single member limited \nliability company (LLC) that did not elect to be taxed as a \ncorporation for federal income tax purposes) is the shareholder \n(owner) of record, enter the name of the disregarded entity.\n• If a nominee or similar person (for example, a guardian, \ncustodian, or agent) is the shareholder (owner) of record, enter \nthe name of the nominee or similar person.\nColumn (c)\nEnter the type of shareholder (owner) of record. For example, \nthe shareholder (owner) of record may be a disregarded entity, \ntrust, estate, nominee, guardian, custodian, agent, or similar \nperson.\nColumn (d)\nEnter the name and SSN or EIN (if any) of the individual or entity \nresponsible for reporting shareholder’s income, deductions, \ncredits, etc., from Schedule K-1 (Form 1120-S). For example:\n1. If a disregarded entity is the shareholder (owner) of record, \nthe owner of the disregarded entity must be eligible to be an \nS corporation shareholder. Enter the name and SSN or EIN (if \nany) of the owner. For example, if a single member LLC owns \nstock in the corporation, and the LLC is treated as a \ndisregarded entity for federal income tax purposes, enter the \nmember’s name and SSN or EIN (if any). An LLC that elects to \nbe treated as a corporation for federal income tax purposes is \nnot eligible to be an S corporation shareholder.\n2. If a trust is the shareholder (owner) of record, the information \nentered in column (d) is dependent on the type of trust.\na. If the trust is a grantor trust, the grantor must be an \nindividual. Enter the name and SSN of the grantor.\nb. If the trust is a qualified subchapter S trust (QSST), there \ncan only be one beneficiary, who must be an individual. Enter \nthe name and SSN of the individual beneficiary.\nc. If the trust is an electing small business trust (ESBT), enter \nthe information you entered under columns (a) and (b). Do not \nenter any beneficiary information. \n3. If an estate is the shareholder (owner) of record, enter the \ninformation you entered under columns (a) and (b). Do not enter \nany beneficiary information.\n" ]
p4327.pdf	1220 Publ 4327 (EN-SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p4327.pdf	[ "Individual Taxpayer\nIdentification Number \n(ITIN)\nNúmero de \nIdentificación Personal \ndel Contribuyente\nEnabling Participation \nin the Tax System\nFacilitando La \nParticipación en el \nSistema Tributario \nFederal\nInformation from the \nInternal Revenue Service\nInformación del \nServicio de Impuestos Internos\t\t\t\n\t\t\t\n", "What is an ITIN and Who Must Apply?\n•\t An Individual Taxpayer Identification Number (ITIN) is a nine-digit\nnumber issued by the Internal Revenue Service (IRS) to individuals\nwho are required for U.S. tax purposes to have a taxpayer identification\nnumber but who do not have, and are not eligible to obtain a Social\nSecurity Number (SSN). The ITIN is for federal tax purposes only.\n•\t Any individual who is not eligible to obtain an SSN but who must\nfurnish a taxpayer identification number must apply for an ITIN the\nmost current version of Form W-7, Application for IRS Individual\nTaxpayer Identification Number.\nHow to Apply\nIf you are applying for an ITIN to file a tax return, you must attach your \noriginal, completed return to Form W-7. After your Form W-7 has been \nprocessed, the IRS will assign an ITIN to the return and process the \nreturn. If you are not required to file a tax return or if you fail to file a \ncompleted tax return with your Form W-7, you will not be issued an ITIN, \nunless you meet one of the exceptions as described in the instructions \nof Form W-7. An ITIN only needs to be renewed if it will be included on a \ntax return. Beginning with tax year 2018, spouses and dependents don't \nneed to renew their ITINs, unless they qualify for an allowable tax benefit \nor file their own tax return.\nSubmit:\n•\t Completed Form W-7.\n•\t Your original, completed tax return(s), if applicable, for which the ITIN\nis needed or exception documentation.\n•\t The original identification documents, or certified copies of documents\nfrom the issuing agency, that substantiate the information provided on\nthe Form W-7. Supporting documentation must prove identity, foreign\nstatus and, if applicable, U.S. residency. If you submit an original valid\npassport or certified copy of a valid passport from the issuing agency,\nyou do not need to submit any other documents from the list below.\nA passport that doesn't have a date of entry won't be accepted as a\nstand-alone identification document for dependents, unless they are\na dependent of U.S. military personnel stationed overseas. In these\ncases, additional original documents must be submitted with the\npassport to prove U.S. residency. See the Instructions for Form W-7\nfor more information. If you do not submit an original valid passport\nor certified copy you must provide a combination of documents (at\nleast two or more) from the list below that are current and that verify:\n(a) your identity, that is, contain your name and a photograph, and (b)\nsupport your claim of foreign status.\n•\t National identification card (must show photo, name, current\t\naddress, date of birth, and expiration date).\n•\t U.S. driver’s license\n•\t Civil birth certificate\n•\t Foreign driver’s license\n•\t U.S. state identification card\n•\t Foreign voter’s registration card\n•\t U.S. military identification card\n•\t Foreign military identification card\n•\t Visa\n•\t U.S. Citizenship and Immigration Services (USCIS) photo identification.\n•\t Medical records (valid only for dependents under age 6)\n•\t School records (valid only for dependents under age 18, if a student)\nWhen to Apply\nComplete and attach Form W-7 when you file the tax return for which the \nITIN is needed. Allow 7 weeks for the IRS to notify you in writing of your \nITIN (9 to 11 weeks if submitted during peak season or from abroad).\nWhere to Apply\nYou can apply for an ITIN in person at a designated IRS Taxpayer \nAssistance Center (service is by appointment only), through an \nAcceptance Agent, or by mail. Visit the IRS website, www.irs.gov for \nTaxpayer Assistance Centers and Acceptance Agent locations.\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\t\n", "¿Qué es el ITIN y quién debe \nsolicitarlo?\n•\t El Número de Identificación Personal del Contribuyente (ITIN, por sus siglas\nen inglés) es un número de nueve dígitos que el Servicio de Impuestos\nInternos (IRS) otorga a quienes están obligados para los propósitos de\nlos impuestos estadounidenses, a tener un número de identificación del\ncontribuyente, pero no tienen, ni pueden obtener un Número de Seguro\nSocial (SSN, por sus siglas en inglés). El ITIN es para usos tributarios\nfederales exclusivamente.\n•\t Toda persona física que no es elegible para obtener un SSN pero debe\nproporcionar un número de identificación, debe solicitar un ITIN mediante \nla versión más reciente del Formulario W-7 (SP), Solicitud de Número de\nIdentificación Personal del Contribuyente del Servicio de Impuestos Internos.\nCómo se solicita\nSi usted solicita un ITIN para presentar una declaración, debe adjuntar su \ndeclaración de impuestos original debidamente completada al Formulario \nW-7(SP). Una vez procesado su Formulario W-7(SP), el IRS le asignará un ITIN \na la declaración y la procesará. Si no está obligado a presentar una declaración,\no no presenta una declaración completada junto con el Formulario W-7(SP), no\nse le asignará el ITIN a menos que usted cumpla con alguna excepción descrita \nen las instrucciones del Formulario W-7 (SP). Sólo tiene que renovar un ITIN si\nse incluirá en una declaración de impuestos. A partir del año tributario 2018, los\ncónyuges y dependientes no tendrán que renovar sus ITIN, a menos que reúnan \nlos requisitos para un beneficio tributario permitido o que presenten sus propias\ndeclaraciones de impuestos.\nEnvíe:\n•\t Su Formulario W-7(SP) completado.\n•\t Su declaración de impuestos original debidamente completada, si es\naplicable, para la cual solicita el ITIN o los documentos que comprueban la \nexcepción.\n•\t Documentos originales o copias certificadas de estos documentos de la\nagencia emisora, que comprueben la información proporcionada en el\nFormulario W-7(SP). La documentación comprobante debe verificar la\nidentidad, condición de extranjero y si se aplica, la residencia estadounidense.\nSi usted proporciona el original de un pasaporte válido o copia certificada del\nmismo, emitida por la agencia emisora, no tiene que proveer ninguno de los\ndocumentos de la siguiente lista. Los pasaportes que no tengan una fecha\nde entrada no se aceptarán como un documento único de identificación para\nlos dependientes, a menos que sean los dependientes del personal militar\nestadounidense estacionado en el extranjero. En estos casos, los documentos\noriginales adicionales deben enviarse junto con el pasaporte para comprobar\nla residencia en los Estados Unidos. Vea las instrucciones en el Formulario\nW-7(SP) para obtener más información. Si no proporciona el original de\nun pasaporte válido o copia certificada, usted debe proporcionar una\ncombinación de varios documentos (por lo menos dos o más) de la siguiente\nlista, que estén vigentes y que verifiquen: a) su identidad, debe contener su\nnombre completo y fotografía; y b) establecer su condición de extranjero(a).\n•\t Tarjeta (Carnet) de identidad nacional (con foto, nombre, domicilio actual,\nfecha de nacimiento y fecha de vencimiento).\n•\t Licencia de conducir de los Estados Unidos.\n•\t Acta de nacimiento civil.\n•\t Licencia de conducir extranjera.\n•\t Carnet de identidad estatal de los Estados Unidos.\n•\t Carnet de registro de votación extranjera.\n•\t Carnet de identidad militar de los Estados Unidos.\n•\t Tarjeta (Carnet) de identidad militar de su país de origen\n•\t Visa\n•\t Identificación con foto del Servicio de Inmigración y Ciudadanía de los\nEstados Unidos (USCIS, por sus siglas en inglés).\n•\t Registros médicos (sólo en el caso de dependientes menores de 6 años de\nedad).\n•\t Registros académicos (sólo en el caso de dependientes menores de 18 años,\nsi son estudiantes).\nCuándo se debe solicitar\nComplete y adjunte el Formulario W-7(SP) al presentar la declaración de \nimpuestos para la cual se necesita un ITIN. Permita 7 semanas para que el IRS \nle notifique por escrito de su ITIN (9 a 11 semanas si envía su solicitud durante \nla temporada alta o desde el extranjero.\n", "Dónde se solicita\nPuede solicitar un ITIN en persona en uno de los Centros de \nAsistencia al Contribuyente del IRS designados (el servicio es \núnicamente por cita), a través de un Agente autorizado, o por \ncorreo. Visite el sitio de Internet del IRS www.irs.gov/es para \nobtener información sobre las oficinas de los Centros de Asistencia \nal Contribuyente y Agentes tramitadores autorizados.\nWhat is an ITIN?\n•\t An IRS individual taxpayer identification number (ITIN) is for\nFederal tax purposes only.\n•\t ITINs are issued to individuals not eligible to obtain a Social\nSecurity Number.\n•\t Getting an ITIN does not change your immigration status or your\nright to work in the United States and does not make you eligible\nfor the Earned Income Credit (EIC), Child Tax Credit (CTC) or\nAdditional Child Tax Credit (ACTC).\n¿Qué es un ITIN?\n•\t El número de identificación personal del contribuyente (ITIN, por\nsus siglas en inglés) es únicamente para propósitos del impuesto\nFederal.\n•\t Los ITINs se otorgan a individuos quienes no son elegibles para\nobtener un número de Seguro Social.\n•\t Obtener un ITIN no cambia su situación migratoria, ni le da el\nderecho a trabajar en los Estados Unidos, ni le hace elegible para\nel Crédito por Ingreso del Trabajo (EIC, por sus siglas en inglés),\nel Crédito Tributario por Hijos (CTC, por sus siglas en inglés), o\nel Crédito Tributario Adicional por Hijos (ACTC, por sus siglas en\ninglés).\nPublication 4327 (en-sp) (Rev. 12-2020) Catalog Number 38458K\nDepartment of the Treasury Internal Revenue Service www.irs.gov\n" ]
f8855.pdf	1220 Form 8855 (PDF)	https://www.irs.gov/pub/irs-pdf/f8855.pdf	[ "Form 8855\n(Rev. December 2020)\nElection To Treat a Qualified Revocable \nTrust as Part of an Estate\nDepartment of the Treasury \nInternal Revenue Service \n ▶ Go to www.irs.gov/Form8855 for the latest information.\nOMB No. 1545-1881\nPart I \nEstate (or Filing Trust) Information \nName of estate (or the filing trust, if applicable (see instructions)) \nEmployer identification number \n(see instructions) \nName of executor (or the filing trustee, if applicable) \nNumber, street, and room or suite no. (or P.O. box number if mail is not delivered to street address) \nCity or town, state, and ZIP code (if a foreign address, see instructions) \nType of entity prior to the election: \nDomestic \nestate \nForeign \nestate \nDomestic \ntrust \nForeign \ntrust \nDate of executor’s appointment \nUnder penalties of perjury, I, as executor (or filing trustee): \n• Confirm that under applicable local law or the governing document, I have the authority to make this election for the estate (if executor) or trust (if \nfiling trustee) and to agree to the conditions of the election; \n• Elect the treatment provided under section 645 for the above-named estate (or filing trust, if applicable); \n• Confirm that an agreement has been reached with the trustees of each qualified revocable trust (QRT) joining in the election to allocate the tax \nburden of the combined electing trusts and related estate, if any, for each tax year during the election period in a manner that reasonably reflects each \nentity’s tax obligation; \n• Agree to ensure that the related estate’s (or filing trust’s, if applicable) share of the tax obligations of the combined electing trust(s) and related estate, \nif any, is timely paid to the United States Treasury; \n• Agree to accept responsibility for filing a complete, accurate, and timely income tax return, when required by law, for the combined electing trust(s) \nand related estate, if any, for each tax year during the election period; \n• (If I am the filing trustee) confirm that if there is more than one QRT making this election, that I have been appointed by the trustees of each QRT \nmaking this election to be the filing trustee and I agree to accept the responsibility of filing the appropriate income tax return for the combined electing \ntrust(s) for each tax year during the election period and all other responsibilities of the filing trustee; \n• (If I am the filing trustee) represent that no executor has been appointed for a related estate and to the best of my knowledge and belief, one will not \nbe appointed; \n• (If I am the filing trustee) agree that, if an executor is appointed for the related estate after this Form 8855 is filed, that I will complete and file an \namended Form 8855 if the late appointed executor agrees to the election, and I agree to cooperate with the executor in filing any amended returns \nrequired to be filed as a result of the executor’s appointment; and \n• Confirm to the best of my knowledge and belief, that all information contained in this election and any accompanying statements or schedules is true, \ncorrect, and complete. \nSignature of executor (or filing trustee) \nDate \nPart II \nDecedent Information \nName of decedent \nSSN of the decedent \nDate of death \nFor Paperwork Reduction Act Notice, see page 4. \nCat. No. 24542R \nForm 8855 (Rev. 12-2020)\n", "Form 8855 (Rev. 12-2020)\nPage 2 \nPart III \nQualified Revocable Trust Information \nName of trust \nEmployer identification number (see instructions)\nName of trustee \nNumber, street, and room or suite no. (or P.O. box number if mail is not delivered to street address) \nCity or town, state, and ZIP code (if a foreign address, see instructions) \nUnder penalties of perjury, I, as trustee of the above-named trust: \n• Confirm that under applicable local law or the governing instrument, I have the authority to make this election for the trust and to agree to the \nconditions of the election; \n• Elect the treatment provided under section 645 for this trust; \n• Agree to timely provide the executor (or filing trustee if there is no executor) with all the trust information necessary to permit the executor (or filing \ntrustee, if applicable) to file a complete, accurate, and timely Form 1041 (or Form 1040-NR for a foreign estate) for the combined electing trust(s) and \nthe related estate, if any, for each tax year during the election period; \n• Confirm that an agreement has been reached with the trustees of each QRT joining in the election, and the executor of the related estate, if any, to \nallocate the tax burden of the combined electing trust(s) and related estate, if any, for each tax year during the election period in a manner that \nreasonably reflects each entity’s tax obligation; \n• Agree to ensure that this trust’s share of the tax obligations of the combined electing trust(s) and related estate, if any, is timely paid to the United \nStates Treasury; \n• Confirm that if a filing trustee (and not an executor for a related estate) has completed Part I of this Form 8855, the trustee that completed Part I has \nbeen appointed the filing trustee, and to the best of my knowledge and belief, an executor has not been appointed to administer a related estate and \none will not be appointed; \n• Agree that if a filing trustee (and not an executor for a related estate) has completed Part I of this Form 8855 and an executor is appointed for the \nrelated estate after this Form 8855 is filed, that I will complete and file an amended Form 8855 if the later appointed executor agrees to the election, \nand I agree to cooperate with the executor in filing any amended returns required to be filed as a result of the executor’s appointment; and \n• Confirm to the best of my knowledge and belief, that all information of the electing trust contained in this election and any accompanying statements \nor schedules is true, correct, and complete. \nSignature of trustee\nDate \nName of trust \nEmployer identification number (see instructions)\nName of trustee \nNumber, street, and room or suite no. (or P.O. box number if mail is not delivered to street address) \nCity or town, state, and ZIP code (if a foreign address, see instructions) \nUnder penalties of perjury, I, as trustee of the above-named trust: \n• Confirm that under applicable local law or the governing instrument, I have the authority to make this election for the trust and to agree to the \nconditions of the election; \n• Elect the treatment provided under section 645 for this trust; \n• Agree to timely provide the executor (or filing trustee if there is no executor) with all the trust information necessary to permit the executor (or filing \ntrustee, if applicable) to file a complete, accurate, and timely Form 1041 (or Form 1040-NR for a foreign estate) for the combined electing trust(s) and \nthe related estate, if any, for each tax year during the election period; \n• Confirm that an agreement has been reached with the trustees of each QRT joining in the election, and the executor of the related estate, if any, to \nallocate the tax burden of the combined electing trust(s) and related estate, if any, for each tax year during the election period in a manner that \nreasonably reflects each entity’s tax obligation; \n• Agree to ensure that this trust’s share of the tax obligations of the combined electing trust(s) and related estate, if any, is timely paid to the United \nStates Treasury; \n• Confirm that if a filing trustee (and not an executor for a related estate) has completed Part I of this Form 8855, the trustee that completed Part I has \nbeen appointed the filing trustee, and to the best of my knowledge and belief, an executor has not been appointed to administer a related estate and \none will not be appointed; \n• Agree that if a filing trustee (and not an executor for a related estate) has completed Part I of this Form 8855 and an executor is appointed for the \nrelated estate after this Form 8855 is filed, that I will complete and file an amended Form 8855 if the later appointed executor agrees to the election, \nand I agree to cooperate with the executor in filing any amended returns required to be filed as a result of the executor’s appointment; and \n• Confirm to the best of my knowledge and belief, that all information of the electing trust contained in this election and any accompanying statements \nor schedules is true, correct, and complete. \nSignature of trustee\nDate \nForm 8855 (Rev. 12-2020)\n", "Form 8855 (Rev. 12-2020) \nPage 3 \nGeneral Instructions \nSection references are to the Internal \nRevenue Code unless otherwise noted. \nFuture Developments\nFor the latest information about \ndevelopments related to Form 8855 and \nits instructions, such as legislation \nenacted after they were published, go to \nwww.irs.gov/Form8855.\nPurpose \nThe trustees of each qualified revocable \ntrust (QRT) and the executor of the \nrelated estate, if any, use Form 8855 to \nmake a section 645 election. This \nelection allows a QRT to be treated and \ntaxed (for income tax purposes) as part \nof its related estate during the election \nperiod. Once the election is made, it \ncannot be revoked. \nDefinitions \nA QRT is any trust (or part of a trust) \nthat, on the day the decedent died, was \ntreated as owned by the decedent under \nsection 676 by reason of a power to \nrevoke that was exercisable by the \ndecedent (determined without regard to \nsection 672(e)). \nFor this purpose, a QRT includes a \ntrust that was treated as owned by the \ndecedent under section 676 by reason of \na power to revoke that was exercisable \nby the decedent with the consent or \napproval of a nonadverse party or the \ndecedent’s spouse. However, a QRT \ndoesn't include a trust that was treated \nas owned by the decedent under section \n676 by reason of a power to revoke that \nwas exercisable solely by a nonadverse \nparty or the decedent’s spouse and not \nby the decedent. \nAn electing trust is a QRT for which a \nvalid section 645 election has been \nmade. Once the QRT makes the \nelection, it is treated as an electing trust \nthroughout the entire election period. \nAn executor is an executor, personal \nrepresentative, or administrator that has \nobtained letters of appointment to \nadminister the decedent’s estate through \nformal or informal appointment \nprocedures. For purposes of this \nelection, an executor doesn't include a \nperson that has actual or constructive \npossession of property of the decedent \nunless that person is appointed or \nqualified as an executor, administrator, \nor personal representative. If more than \none jurisdiction has appointed an \nexecutor, then, for purposes of this \nelection, only the person from the \nprimary or domiciliary proceeding is the \nexecutor. \nA related estate is the estate of the \ndecedent who was treated as the owner \nof the QRT on the date of the decedent’s \ndeath. \nA filing trustee is the trustee of an \nelecting trust who, when there is no \nexecutor, has been appointed by the \ntrustees of each of the other electing \ntrusts to file the Forms 1041 (or 1040-NR, \nif applicable) due for the combined \nelecting trust(s) for each tax year during \nthe election period and has agreed to \naccept that responsibility. If there is no \nexecutor and there is only one QRT \nmaking the section 645 election, the \ntrustee of that electing trust is the filing \ntrustee. \nA filing trust is an electing trust whose \ntrustee was appointed as the filing \ntrustee by all electing trusts if there is no \nexecutor. If there is no executor and only \none QRT is making the election, that \nQRT is the filing trust. \nElection Period \nThe election period is the period of time \nduring which an electing trust is treated \nand taxed as part of its related estate. \nThe election period begins on the date \nof the decedent’s death and terminates \non the earlier of: \n• The day on which each electing trust \nand the related estate, if any, have \ndistributed all of their assets; or \n• The day before the applicable date. \nApplicable date. To determine the \napplicable date, you must first determine \nwhether a Form 706, United States \nEstate (and Generation-Skipping \nTransfer) Tax Return, is required to be \nfiled as a result of the decedent’s death. \nIS a Form 706 \nrequired? \nTHEN the \napplicable date is... \nYes \nThe later of: \n• 2 years after the date of \nthe decedent’s death or \n• 6 months after the final \ndetermination of liability \nfor estate tax. \nNo \n2 years after the date of \nthe decedent’s death. \nFinal determination of liability. For \npurposes of this election only, the date \nof final determination of liability for the \nestate tax is the earliest of: \n• 6 months after the IRS issues an estate \ntax closing letter (unless a claim for \nrefund of estate tax is filed within 12 \nmonths after the letter is issued); \n• The final disposition of a claim for \nrefund that resolves the liability for the \nestate tax (unless suit is instituted within \n6 months after a final disposition of the \nclaim); \n• The execution of a settlement \nagreement with the IRS that determines \nthe liability for the estate tax; \n• The issuance of a decision, judgment, \ndecree, or other order by a court of \ncompetent jurisdiction resolving the \nliability for the estate tax (unless a notice \nof appeal or a petition for certiorari is \nfiled within 90 days after the issuance of \na decision, judgment, decree, or other \norder of a court); or \n• The expiration of the period of \nlimitations for the estate tax. \nWhen To File \nFile the election by the due date \n(including extensions, if any) of the Form \n1041 (or Form 1040-NR, if applicable) for \nthe first tax year of the related estate (or \nthe filing trust). This applies even if the \ncombined related estate and electing \ntrust(s) don't have sufficient income to \nbe required to file Form 1041. \nIn general, the due date for the first \nincome tax return is the 15th day of the \n4th month after the close of the first tax \nyear of the related estate. For \nexceptions, see Regulations section \n1.6072-1(c). For the purpose of \ndetermining the tax year if there is no \nexecutor, treat the filing trust as an \nestate. If the estate is granted an \nextension of time to file its income tax \nreturn for its first tax year, the due date \nof the Form 8855 is the extended due \ndate. \nFor instructions on when to file an \namended election, see Amended \nElection Needed When an Executor Is \nAppointed After a Valid Election Is Made \non page 4. \nWhere To File \nIF you are \nlocated in... \nTHEN send the election \nto the... \nConnecticut, \nDelaware, District of \nColumbia, Georgia, \nIllinois, Indiana, \nKentucky, Maine, \nMaryland, \nMassachusetts, \nMichigan, \nNew Hampshire, \nNew Jersey, \nNew York, \nNorth Carolina, \nOhio, Pennsylvania, \nRhode Island, \nSouth Carolina, \nTennessee, \nVermont, Virginia, \nWest Virginia, \nWisconsin \nDepartment of the Treasury \nInternal Revenue Service Center \nKansas City, MO 64999 \nAlabama, Alaska, \nArizona, Arkansas, \nCalifornia, \nColorado, Florida, \nHawaii, Idaho, Iowa, \nKansas, Louisiana, \nMinnesota, \nMississippi, \nMissouri, Montana, \nNebraska, Nevada, \nNew Mexico, \nNorth Dakota, \nOklahoma, Oregon, \nSouth Dakota, \nTexas, Utah, \nWashington, \nWyoming \nA foreign country or \na U.S. possession \nDepartment of the Treasury \nInternal Revenue Service Center \nOgden, UT 84201 \n", "Form 8855 (Rev. 12-2020)\nPage 4 \nWho Must Sign \nIf there is more than one executor for a \nrelated estate or more than one trustee \nfor an electing trust, only one executor or \ntrustee must sign Form 8855 on behalf \nof the entity, unless otherwise required \nby applicable local law or the governing \ndocument. \nEmployer Identification \nNumbers \nThe trustee of a QRT must obtain a new \nemployer identification number (EIN) for \nthe QRT upon the death of the decedent. \nParts I and III require that a trustee enter \nthe EIN obtained by the trustee following \nthe death of the decedent. See \nRegulations section 301.6109-1. \nRetention of Copy of Form \n8855 \nThe executor of the related estate, if any, \nand the trustee of each electing trust \nmust retain a copy of the completed \nForm 8855 (and any amended Form \n8855 required to be filed) and retain \nproof that the Form 8855 was timely \nfiled. \nTax Treatment \nDuring the election period, all electing \ntrusts and the related estate, if any, file \none combined income tax return. For \npurposes of that return, the electing \ntrusts and the related estate are treated \nas one estate. For example, the electing \ntrust(s) are treated as part of the estate \nfor purposes of adopting a tax year, for \ndetermining whether estimated tax \npayments are required, the set-aside \ndeduction under section 642(c)(2), the S \ncorporation shareholder requirements of \nsection 1361(b)(1), and the special \nallowance for rental real estate activities \nunder section 469(i)(4). \nNote, however, that each electing trust \nand the related estate are treated as a \nseparate share for purposes of the \nseparate share rules under section \n663(c) when the combined entity \ncomputes distributable net income and \napplies the distribution rules. \nAmended Election Needed \nWhen an Executor Is \nAppointed After a Valid \nElection Is Made \nIf Form 8855 was filed by the filing \ntrustee because there was no executor \nand an executor is subsequently \nappointed, an amended election must be \ntimely made. Otherwise, the election \nperiod terminates the day before the \nexecutor is appointed. \nHow to make an amended election. \nThe executor and the trustees of each \nelecting trust complete and file a new \nForm 8855 and write “AMENDED \nELECTION” at the top of the form. \nWhen to file an amended election. File \nan amended Form 8855 within 90 days \nof the appointment of the executor. \nCorrection of returns. See the \nInstructions for Form 1041 and \nRegulations section 1.645-1 for \ninformation on amending the previously \nfiled returns. \nOther Information \nFor additional information about the \nreporting rules for a QRT, an electing \ntrust, or a former electing trust, or \ninformation about when it is necessary to \nobtain a new EIN, see the Instructions \nfor Form 1041 and Regulations section \n1.645-1. \nSpecific Instructions \nPart I \nThe executor of the related estate \ncompletes the information requested in \nthis part and attests to the making of this \nelection and the conditions for a valid \nsection 645 election by signing (under \npenalties of perjury) and dating the form \nin the space provided. \nIf there is no executor, the filing \ntrustee completes the information and \nattests to the making of this election and \nthe conditions for a valid section 645 \nelection by signing (under penalties of \nperjury) and dating the form in the space \nprovided. \nThe executor must obtain an EIN for \nthe estate prior to filing this election. A \nfiling trustee must enter the new EIN \nobtained for the trust after the \ndecedent’s death in the space for \nEmployer identification number in Part I. \nIf you have a foreign address, enter \nthe information in the following order: \ncity, province or state, and country. \nFollow the country’s practice for entering \nthe postal code. Don’t abbreviate the \ncountry name. \nPart II \nThe executor (or filing trustee if there is \nno executor) completes this section. \nPart III \nThe trustee for each QRT that is joining in \nthe election completes the information \nrequested in this part and attests to the \nmaking of this election and the conditions \nfor a valid section 645 election by signing \n(under penalties of perjury) and dating the \nform in the space provided. \nCaution: A QRT must get a new EIN \nfollowing the death of the decedent. \nIn the space for Employer \nidentification number, be sure to enter \nthe new EIN obtained for the trust after \nthe decedent’s death. \nSpace is provided for two QRTs. If \nmore than two QRTs are joining in the \nelection than space provided, use \nadditional Part(s) III. If additional pages \nof Part III are attached, the executor (or \nfiling trustee) should indicate on the top \nof the first page of Part III how many \nadditional pages are attached and the \ntotal number of QRTs joining in the \nelection. \nPaperwork Reduction Act Notice. We \nask for the information on this form to \ncarry out the Internal Revenue laws of \nthe United States. You are required to \ngive us the information. We need it to \nensure that you are complying with these \nlaws and to allow us to figure and collect \nthe right amount of tax. \nYou are not required to provide the \ninformation requested on a form that is \nsubject to the Paperwork Reduction Act \nunless the form displays a valid OMB \ncontrol number. Books or records \nrelating to a form or its instructions must \nbe retained as long as their contents \nmay become material in the \nadministration of any Internal Revenue \nlaw. Generally, tax returns and return \ninformation are confidential, as required \nby section 6103. \nThe time needed to complete and file \nthis form will vary depending on \nindividual circumstances. The estimated \naverage time is: \nRecordkeeping .\n.\n.\n. 3 hr., 21 min. \nLearning about \nthe law or the form \n.\n. 1 hr., 5 min.\nPreparing, copying, \nassembling, and \nsending the form \nto the IRS .\n.\n.\n.\n.\n. 1 hr., 11 min.\nIf you have comments concerning the \naccuracy of these time estimates or \nsuggestions for making this form \nsimpler, we would be happy to hear from \nyou. You can write to the Internal \nRevenue Service, Tax Products \nCoordinating Committee, \nSE:W:CAR:MP:T:T:SP, 1111 Constitution \nAve. NW, IR-6526, Washington, DC \n20224. Don’t send the tax form to this \naddress. Instead, see Where To File on \npage 3. \n" ]
f8869.pdf	1220 Form 8869 (PDF)	https://www.irs.gov/pub/irs-pdf/f8869.pdf	[ "Form 8869\n(Rev. December 2020)\nQualified Subchapter S Subsidiary Election\nDepartment of the Treasury \nInternal Revenue Service \n(Under section 1361(b)(3) of the Internal Revenue Code) \n▶ Go to www.irs.gov/Form8869 for instructions and the latest information.\nOMB No. 1545-0123\nPart I \nParent S Corporation Making the Election \n1a Name of parent \nb Number, street, and room or suite no. If a P.O. box, see instructions. \nc City or town, state or province, country, and ZIP or foreign postal code\n2 Employer identification number (EIN) \n3 Tax year ending (month and day) \n4 Service center where last return was filed \n5 Name and title of officer or legal representative whom the IRS may call for more information \n6 Telephone number of officer or legal \nrepresentative\nPart II \nSubsidiary Corporation for Which Election is Made (For additional subsidiaries, see instructions.) \n7a Name of subsidiary \nb Number, street, and room or suite no. If a P.O. box, see instructions. \nc City or town, state or province, country, and ZIP or foreign postal code \n8 EIN (if any) \n9 Date incorporated \n10 State of incorporation \n11 Date election is to take effect (month, day, year) (see instructions) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\n12\nDid the subsidiary previously file a federal income tax return? If “Yes,” complete lines 13a, 13b, and 13c \n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶ \nYes \nNo \n13a Service center where last return was filed \n13b Tax year ending date of last \nreturn (month, day, year) ▶\n13c Check type of return filed: \nForm 1120 \nForm 1120-S \nOther ▶\n14 Is this election being made in combination with a section 368(a)(1)(F) reorganization described in Rev. Rul. 2008-18, where the subsidiary was \nan S corporation immediately before the election and a newly formed holding company will be the subsidiary’s parent? \n.\n.\n.\n.\n.\n ▶ \nYes \nNo \n15 Was the subsidiary’s last return filed as part of a consolidated return? If “Yes,” complete lines 16a, 16b, and 16c .\n.\n.\n.\n.\n.\n.\n ▶ \nYes \nNo \n16a Name of common parent \n16b EIN of common parent \n16c Service center where consolidated return was filed \nUnder penalties of perjury, I declare that I have examined this election, including accompanying statements, and to the best of my knowledge and belief, it is true, correct, \nand complete. \nSignature of officer \nof parent corporation ▶\nTitle ▶\nDate ▶\nFor Paperwork Reduction Act Notice, see separate instructions.\nCat. No. 28755K\nForm 8869 (Rev. 12-2020) \n" ]
f8849s2.pdf	1220 Form 8849 (Schedule 2) (PDF)	https://www.irs.gov/pub/irs-pdf/f8849s2.pdf	[ "Schedule 2 \n(Form 8849) \n(Rev. December 2020) \nDepartment of the Treasury \nInternal Revenue Service \nSales by Registered Ultimate Vendors \n▶ Attach to Form 8849. Do not file with any other schedule. \n▶ Go to www.irs.gov/Form8849 for the latest information. \nOMB No. 1545-1420 \nName as shown on Form 8849 \nEIN \nTotal refund (see instructions) \n$ \nPeriod of claim: Enter month, day, and year \nin MMDDYYYY format. \nFrom ▶\nTo ▶\nClaimant’s registration no. ▶\nU V \nComplete for lines 1a, 2a, 4a, 4b, 5a, and 5b. Also \ncomplete for lines 3d and 3e, type of use 14. \nNote: UV claimant must complete line 6 or 7 on page 3. \n▶\nU B \nComplete for lines 1b and 2c. \n▶\nU P \nComplete for line 2b. \n▶\nU A \nComplete for line 3. See UV for lines 3d and 3e, type of \nuse 14. \n1 \nSales by Registered Ultimate Vendors of Undyed Diesel Fuel \nClaimant sold the diesel fuel at a tax-excluded price, repaid the amount of tax to the buyer, or obtained written consent \nof the buyer to make the claim. For line 1a, claimant has obtained the required certificate from the buyer and has no \nreason to believe any information in the certificate is false. For line 1b, the registered ultimate vendor is eligible to make \nthis claim only if the buyer waives their right to make the claim by providing the registered ultimate vendor with an \nunexpired waiver and has no reason to believe any of the information in the waiver is false. See the instructions for \nadditional information to be submitted. \nClaimant certifies that the diesel fuel did not contain visible evidence of dye. \nException. If any of the diesel fuel included in this claim did contain visible evidence of dye, attach an explanation and \ncheck here \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\nCaution: Claims cannot be made on line 1a for diesel fuel purchased by a state or local government for its exclusive use\nwith a credit card issued to the state or local government by a credit card issuer. \n(a) Rate \n(b) Gallons \n(c) Amount of refund \nMultiply col. (a) by col. (b) \n(d) \nCRN \na Use by a state or local government \n$.243\n$ \n360\nb Use in certain intercity and local \nbuses \n.17\n350\n2 \nSales by Registered Ultimate Vendors of Undyed Kerosene (Other Than Kerosene For Use in Aviation) \nClaimant sold the kerosene at a tax-excluded price, repaid the amount of tax to the buyer, or obtained written consent of\nthe buyer to make the claim. For line 2a, claimant has obtained the required certificate from the buyer and has no reason\nto believe any information in the certificate is false. For line 2b, claimant has a statement, if required, that contains the\ndate of sale, name and address of the buyer, and the number of gallons of kerosene sold to the buyer. For line 2c, the\nregistered ultimate vendor is eligible to make this claim only if the buyer waives their right to make the claim by providing \nthe registered ultimate vendor with an unexpired waiver and has no reason to believe any of the information in the waiver \nis false. See the instructions for additional information to be submitted. \nClaimant certifies that the kerosene did not contain visible evidence of dye. \nException. If any of the kerosene included in this claim did contain visible evidence of dye, attach an explanation and \ncheck here \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\nCaution: Claims cannot be made on line 2a for kerosene purchased by a state or local government for its exclusive use \nwith a credit card issued to the state or local government by a credit card issuer. \n(a) Rate \n(b) Gallons \n(c) Amount of refund \nMultiply col. (a) by col. (b) \n(d) \nCRN \na Use by a state or local government \n$.243\n$ \n346\nb Sales from a blocked pump \n.243\nc Use in certain intercity and local buses \n.17\n347\nFor Privacy Act and Paperwork Reduction Act Notice, see the Form 8849 instructions. \nCat. No. 27450U\nSchedule 2 (Form 8849) (Rev. 12-2020) \n", "Schedule 2 (Form 8849) (Rev. 12-2020) \nPage 2 \nName as shown on Form 8849 \nEIN \n3 \nSales by Registered Ultimate Vendors of Kerosene for Use in Aviation \nClaimant sold the kerosene for use in aviation at a tax-excluded price and has not collected the amount of tax from the \nbuyer, repaid the amount of tax to the buyer, or has obtained written consent of the buyer to make the claim. For lines \n3a, 3b, 3d, 3e, and 3f, the registered ultimate vendor is eligible to make this claim only if the buyer waives their right to \nmake the claim by providing the registered ultimate vendor with an unexpired waiver and has no reason to believe any of\nthe information in the waiver is false. For line 3c, claimant has obtained the required certificate from the buyer and has no \nreason to believe any of the information in the certificate is false. See the instructions for additional information to be\nsubmitted. See the instructions for sales of kerosene used in commercial aviation from March 28, 2020, through\nDecember 31, 2020.\nType of \nuse \n(a) \nRate \n(b) \nGallons \n(c) \nAmount of refund \nMultiply col. (a) \nby col. (b) \n(d) \nCRN \na Use in commercial aviation (other than foreign trade) \ntaxed at $.219 \n$.175\n$ \n355\nb Use in commercial aviation (other than foreign trade) \ntaxed at $.244 \n.200\n417\nc Nonexempt use in noncommercial aviation \n.025\n418\nd Other nontaxable uses taxed at $.244 \n.243\n346\ne Other nontaxable uses taxed at $.219 \n.218\n369\nf\nLUST tax on aviation fuels used in foreign trade \n.001\n433\n4 \nSales by Registered Ultimate Vendors of Gasoline \nClaimant sold the gasoline at a tax-excluded price and has not collected the amount of tax from the buyer, repaid the \namount of tax to the buyer, or has obtained written consent of the buyer to make the claim; and obtained an unexpired \ncertificate from the buyer and has no reason to believe any information in the certificate is false. See the instructions for \nadditional information to be submitted. \nCaution: Claims cannot be made on line 4a or 4b for gasoline purchased by a state or local government or a nonprofit \neducational organization for its exclusive use with a credit card issued to the state or local government or nonprofit \neducational organization by the credit card issuer. \n(a) Rate \n(b) Gallons \n(c) Amount of refund \nMultiply col. (a) by col. (b) \n(d) \nCRN \na Use by a nonprofit educational organization \n$.183\n$ \n362\nb Use by a state or local government \n.183\n5 \nSales by Registered Ultimate Vendors of Aviation Gasoline \nClaimant sold the aviation gasoline at a tax-excluded price and has not collected the amount of tax from the buyer, \nrepaid the amount of tax to the buyer, or has obtained written consent of the buyer to make the claim; and obtained an \nunexpired certificate from the buyer and has no reason to believe any information in the certificate is false. See the \ninstructions for additional information to be submitted. \nCaution: Claims cannot be made on line 5a or 5b for aviation gasoline purchased by a state or local government or a \nnonprofit educational organization for its exclusive use with a credit card issued to the state or local government or \nnonprofit educational organization by the credit card issuer. \n(a) Rate \n(b) Gallons \n(c) Amount of refund \nMultiply col. (a) by col. (b) \n(d) \nCRN \na Use by a nonprofit educational organization \n$.193\n$ \n324\nb Use by a state or local government \n.193\nSchedule 2 (Form 8849) (Rev. 12-2020) \n", "Schedule 2 (Form 8849) (Rev. 12-2020) \nPage 3 \nName as shown on Form 8849 \nEIN \n6 \nGovernment Unit Information \nComplete if making a claim on lines 1a or 2a; or lines 3d and 3e for type of use 14. Enter the information below for each \ngovernmental unit to whom the fuel was sold. If more space is needed, attach additional sheets. \nTaxpayer Identification No. \nName \nGallons \n7 \nNonprofit Educational Organization and Government Unit Information \nComplete if making a claim on line 4a, 4b, 5a, or 5b. Enter the information below for each nonprofit educational organization or \ngovernmental unit to whom the gasoline or aviation gasoline was sold. If more space is needed, attach additional sheets. \nTaxpayer Identification No. \nName \nGallons \nSchedule 2 (Form 8849) (Rev. 12-2020) \n", "Schedule 2 (Form 8849) (Rev. 12-2020) \nPage 4 \nWhat’s New \nTax holiday for sales of kerosene used in commercial aviation. \nSales of kerosene used in commercial aviation from March 28, \n2020, through December 31, 2020, (tax holiday) are treated as a \nnontaxable use. Go to www.irs.gov/newsroom/faqs-aviation-excise-\ntax-holiday-under-the-cares-act for answers to frequently asked \nquestions (FAQs). See Reminders and the instructions for lines 3a \nand 3b.\nReminders \n• Registered ultimate vendors of kerosene sold for nontaxable use \nin noncommercial aviation are eligible to make a claim on lines 3d \nand 3e only if the buyer waives his or her right to make the claim by \nproviding the registered ultimate vendor with an unexpired waiver. \n• Registered ultimate vendors of kerosene sold for use in foreign \ntrade are eligible to make a claim on line 3f for the leaking \nunderground storage tank (LUST) tax if the buyer waives his or her \nright to make the claim by providing the registered ultimate vendor \nwith an unexpired waiver. \n• Registered ultimate vendors cannot make claims for certain uses \nof taxable fuel if the ultimate purchaser purchased the fuel with a \ncredit card issued to the ultimate purchaser by the credit card \nissuer. See the Cautions above lines 1a, 2a, 4a, and 5a. \nGeneral Instructions \nPurpose of Schedule \nA registered ultimate vendor of undyed diesel fuel, undyed \nkerosene, kerosene sold for use in aviation, gasoline, or aviation \ngasoline uses Schedule 2 to make a claim for refund. \nSee Registration Number below if you do not have a valid \nregistration number. \nTotal Refund \nAdd all amounts in column (c) and enter the result in the total \nrefund box at the top of the schedule. \nRegistration Number \nYou must enter your registration number. You are registered if you \nreceived a letter of registration with a registration number from the \nIRS that has not been revoked or suspended. See the list below. If \nyou do not have a registration number, you cannot make this claim. \nUse Form 637, Application for Registration (For Certain Excise Tax \nActivities), to apply for one. \n• UV. Ultimate vendor that sells undyed diesel fuel, undyed \nkerosene, gasoline, or aviation gasoline; lines 1a, 2a, 4a, 4b, 5a, and \n5b; and lines 3d and 3e, type of use 14. \n• UB. Ultimate vendor that sells undyed diesel fuel or undyed \nkerosene for use in certain intercity and local buses; lines 1b and \n2c. \n• UP. Ultimate vendor that sells kerosene sold from a blocked \npump; line 2b. \n• UA. Ultimate vendor that sells kerosene for use in aviation; lines \n3a–3f. See UV above for lines 3d and 3e, type of use 14. \nRequired Certificate or Waiver \nThe required certificates or waivers are listed in the line instructions \nand are available in Pub. 510. \nHow To File \nAttach Schedule 2 to Form 8849. On the envelope, write \n“Registered Ultimate Vendor Claim” and mail to the IRS at the \naddress under Where To File in the Form 8849 instructions. \nSpecific Instructions \nLine 1a. Sales by Registered Ultimate Vendors of Undyed \nDiesel Fuel \nClaimant. The registered ultimate vendor of the diesel fuel is the \nonly person eligible to make this claim and has obtained the \nrequired certificate from the buyer and has no reason to believe any \ninformation in the certificate is false. See Model Certificate P in Pub. \n510. Only one claim may be filed with respect to any gallon of diesel \nfuel. \nAllowable sales. The diesel fuel must have been sold during the \nperiod of claim by the registered ultimate vendor for the exclusive \nuse by a state or local government (including essential government \nuse by an Indian tribal government). \nClaim requirements. The following requirements must be met. \n1. The claim must be for diesel fuel sold during a period that is at \nleast 1 week. \n2. The amount of the claim must be at least $200. To meet this \nminimum, amounts from lines 1, 2, and 3 may be combined. \n3. The claim must be filed by the last day of the first quarter \nfollowing the earliest quarter of the claimant’s income tax year \nincluded in the claim. For example, a calendar-year claimant’s \nclaim for diesel fuel sold during September and October must be \nfiled by December 31. \nNote. If requirements 1–3 above are not met, see Annual Claims \nunder Additional Information for Schedules 1, 2, and 3 in the Form \n8849 instructions. \nInformation to be submitted. Complete Line 6, Government Unit \nInformation, for each governmental unit to whom the diesel fuel was \nsold and the number of gallons sold to each. If more space is \nneeded, attach additional sheets. \nLine 1b. Sales by Registered Ultimate Vendors of Undyed \nDiesel Fuel for Use in Certain Intercity and Local Buses \nClaimant. The registered ultimate vendor of the diesel fuel is \neligible to make a claim on line 1b only if the buyer waives his or \nher right to make the claim by providing the registered ultimate \nvendor with an unexpired waiver. See Model Waiver N in Pub. 510. \nOnly one claim may be filed with respect to any gallon of diesel fuel. \nClaim requirements. The following requirements must be met. \n1. The claim must be for diesel fuel sold during a period that is at \nleast 1 week. \n2. The amount of the claim must be at least $200. To meet this \nminimum, amounts from lines 1, 2, and 3 may be combined. \n3. The claim must be filed by the last day of the first quarter \nfollowing the earliest quarter of the claimant’s income tax year \nincluded in the claim. For example, a calendar-year claimant’s \nclaim for diesel fuel sold during September and October must be \nfiled by December 31. \nNote. If requirements 1–3 above are not met, see Annual Claims \nunder Additional Information for Schedules 1, 2, and 3 in the Form \n8849 instructions. \nLines 2a and 2b. Sales by Registered Ultimate Vendors of \nUndyed Kerosene (Other Than Kerosene For Use in \nAviation) \nClaimant. For line 2a, the registered ultimate vendor of the \nkerosene is the only person eligible to make this claim and has \nobtained the required certificate from the buyer and has no reason \nto believe any information in the certificate is false. See Model \nCertificate P in Pub. 510. For line 2b, claimant has a statement, if \nrequired, that contains the date of sale, name and address of the \nbuyer, and the number of gallons of kerosene sold to the buyer. For \nlines 2a and 2b, only one claim may be filed with respect to any \ngallon of kerosene. \nAllowable sales. For line 2a, the kerosene must have been sold by \nthe registered ultimate vendor during the period of claim for the \nexclusive use by a state or local government (including essential \ngovernment use by an Indian tribal government). For line 2b, the \nkerosene must have been sold during the period of claim from a \nblocked pump. \nClaim requirements. The following requirements must be met. \n1. The claim must be for kerosene sold during a period that is at \nleast 1 week. \n2. The amount of the claim must be at least $100. To meet this \nminimum, amounts from lines 2 and 3 may be combined. \n", "Schedule 2 (Form 8849) (Rev. 12-2020) \nPage 5 \n3. The claim must be filed by the last day of the first quarter \nfollowing the earliest quarter of the claimant’s income tax year \nincluded in the claim. For example, a calendar-year claimant’s claim \nfor kerosene sold during September and October must be filed by \nDecember 31. \nNote. If requirements 1–3 above are not met, see Annual Claims \nunder Additional Information for Schedules 1, 2, and 3 in the Form \n8849 instructions. \nInformation to be submitted. For claims on line 2a, complete Line \n6, Government Unit Information, for each governmental unit to \nwhom the kerosene was sold and the number of gallons sold to \neach. \nLine 2c. Sales by Registered Ultimate Vendors of Undyed \nKerosene for Use in Certain Intercity and Local Buses \nClaimant. The registered ultimate vendor of the kerosene is eligible \nto make a claim on line 2c only if the buyer waives his or her right to \nmake the claim by providing the registered ultimate vendor with an \nunexpired waiver. See Model Waiver N in Pub. 510. Only one claim \nmay be filed with respect to any gallon of kerosene. \nClaim requirements. The following requirements must be met. \n1. The claim must be for kerosene sold during a period that is at \nleast 1 week. \n2. The amount of the claim must be at least $100. To meet this \nminimum, amounts from lines 2 and 3 may be combined. \n3. The claim must be filed by the last day of the first quarter \nfollowing the earliest quarter of the claimant’s income tax year \nincluded in the claim. For example, a calendar-year claimant’s claim \nfor diesel fuel sold during September and October must be filed by \nDecember 31. \nNote. If requirements 1–3 above are not met, see Annual Claims \nunder Additional Information for Schedules 1, 2, and 3 in the Form \n8849 instructions. \nLines 3a and 3b. Sales by Registered Ultimate Vendors of \nKerosene For Use in Commercial Aviation (Other Than \nForeign Trade) \n▲\n!\nCAUTION\nSales of kerosene used in commercial aviation from March \n28, 2020, through December 31, 2020 (tax holiday); report \nclaims using type of use 15. To make a claim, use type of use 15, \non lines 3d or 3e, depending on the tax rate paid. Claimants must \nattach a statement explaining that the claim is for the relief provided \nby the tax holiday. See Reminders, earlier; Lines 3c, 3d, 3e, and 3f., \nbelow; and the claimant requirements for lines 3a and 3b, below.\nClaimant. The registered ultimate vendor of the kerosene sold for \nuse in commercial aviation (other than foreign trade) is eligible to \nmake this claim only if the buyer waives his or her right by providing \nthe registered ultimate vendor with an unexpired waiver. See Model \nWaiver L in Pub. 510. Only one claim may be filed with respect to \nany gallon of kerosene. \nClaim requirements. The following requirements must be met. \n1. The claim must be for kerosene sold during a period that is at \nleast 1 week. \n2. The amount of the claim must be at least $100. To meet this \nminimum, amounts from lines 2 and 3 may be combined. \n3. The claim must be filed by the last day of the first quarter \nfollowing the earliest quarter of the claimant’s income tax year \nincluded in the claim. For example, a calendar-year claimant’s claim \nfor kerosene sold during September and October must be filed by \nDecember 31. \nNote. If requirements 1–3 above are not met, see Annual Claims \nunder Additional Information for Schedules 1, 2, and 3 in the Form \n8849 instructions. \nLines 3c, 3d, 3e, and 3f. Sales by Registered Ultimate \nVendors of Kerosene For Use in Noncommercial Aviation \nand for Use in Commercial Aviation During Tax Holiday\n▲\n!\nCAUTION\nSales of kerosene used in commercial aviation from March \n28, 2020, through December 31, 2020 (tax holiday); report \nclaims using type of use 15. To make a claim, use type of use 15, \non line 3d or 3e, depending on the tax rate paid. Claimants must\nattach a statement explaining that the claim is for the relief provided \nby the tax holiday. See Reminders, earlier, and the claimant \nrequirements for lines 3a and 3b, earlier.\nClaimant. For line 3c, the registered ultimate vendor of the \nkerosene sold for use in nonexempt, noncommercial aviation is the \nonly person eligible to make this claim and has obtained the \nrequired certificate from the ultimate purchaser. See Model \nCertificate Q in Pub. 510. For lines 3d, 3e, and 3f, the registered \nultimate vendor of the kerosene sold for nontaxable use in \nnoncommercial aviation (foreign trade for line 3f) is eligible to make \nthis claim only if the buyer waives his or her right to make the claim \nby providing the registered ultimate vendor with an unexpired \nwaiver. For type of use 1, 9, 10, 11, 13, 15, or 16, see Model Waiver \nL in Pub. 510. For type of use 14, see Model Certificate P in Pub. \n510. Only one claim may be filed with respect to any gallon of \nkerosene sold for use in noncommercial aviation. \nAllowable sales. For line 3c, the kerosene must have been sold \nduring the period of claim for a nonexempt use in noncommercial \naviation. For lines 3d and 3e, the kerosene sold for use in \nnoncommercial aviation must have been sold during the period of \nclaim for type of use 1, 9, 10, 11, 13, 14, 15, or 16. For line 3f, the \nkerosene sold for use in noncommercial aviation must have been \nsold during the period of claim for type of use 9. This claim is made \nin addition to the claim made on lines 3d and 3e for type of use 9. \nClaim requirements. The following requirements must be met. \n1. The claim must be for kerosene sold for use in noncommercial \naviation during a period that is at least 1 week. \n2. The amount of the claim must be at least $100. To meet this \nminimum, amounts from lines 2 and 3 may be combined. \n3. The claim must be filed by the last day of the first quarter \nfollowing the earliest quarter of the claimant’s income tax year \nincluded in the claim. For example, a calendar-year claimant’s claim \nfor kerosene sold during September and October must be filed by \nDecember 31. \nNote. If requirements 1–3 above are not met, see Annual Claims \nunder Additional Information for Schedules 1, 2, and 3 in the Form \n8849 instructions. \nInformation to be submitted. For claims on lines 3d and 3e (type \nof use 14), complete Line 6, Government Unit Information, for each \ngovernmental unit to whom the kerosene was sold and the number \nof gallons sold to each. \nLines 4a, 4b, 5a, and 5b. Sales by Registered Ultimate \nVendors of Gasoline or Aviation Gasoline \nClaimant. The registered ultimate vendor of the gasoline or aviation \ngasoline is eligible to make a claim on lines 4a, 4b, 5a, and 5b if the \nultimate purchaser waives his or her right to make the claim by \nproviding the registered ultimate vendor with an unexpired \ncertificate. See Model Certificate M in Pub. 510. Only one claim may \nbe filed with respect to any gallon of gasoline or aviation gasoline. \nAllowable sales. The gasoline or aviation gasoline must have been \nsold during the period of claim for: \n• Use by a nonprofit educational organization, or \n• Use by a state or local government (including essential \ngovernment use by an Indian tribal government). \nClaim requirements. The following requirements must be met. \n1. The claim must be for gasoline or aviation gasoline sold during \na period that is at least 1 week. \n2. The amount of the claim must be at least $200. To meet this \nminimum, amounts from lines 4a, 4b, 5a, and 5b may be combined. \n3. The claim must be filed by the last day of the first quarter \nfollowing the earliest quarter of the claimant’s income tax year \nincluded in the claim. For example, a calendar-year claimant’s claim \nfor gasoline or aviation gasoline sold during September and \nOctober must be filed by December 31. \nInformation to be submitted. Complete Line 7, Nonprofit \nEducational Organization and Government Unit Information, for \neach nonprofit educational organization or governmental unit to \nwhom the gasoline or aviation gasoline was sold and the number of \ngallons sold to each. \n" ]
i2553.pdf	1220 Inst 2553 (PDF)	https://www.irs.gov/pub/irs-pdf/i2553.pdf	[ "Instructions for Form 2553\n(Rev. December 2020)\n(For use with the December 2017 revision of Form 2553, Election by a Small \nBusiness Corporation)\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nFor the latest information about developments related to \nForm 2553 and its instructions, such as legislation enacted \nafter they were published, go to IRS.gov/Form2553.\nGeneral Instructions\nPurpose of Form\nA corporation or other entity eligible to elect to be treated as \na corporation must use Form 2553 to make an election under \nsection 1362(a) to be an S corporation. An entity eligible to \nelect to be treated as a corporation that meets certain tests \ndiscussed below will be treated as a corporation as of the \neffective date of the S corporation election and doesn’t need \nto file Form 8832, Entity Classification Election.\nThe income of an S corporation generally is taxed to the \nshareholders of the corporation rather than to the corporation \nitself. However, an S corporation may still owe tax on certain \nincome. For details, see Tax and Payments in the \nInstructions for Form 1120-S, U.S. Income Tax Return for an \nS Corporation.\nWho May Elect\nA corporation or other entity eligible to elect to be treated as \na corporation may elect to be an S corporation only if it meets \nall the following tests.\n1. It is (a) a domestic corporation, or (b) a domestic entity \neligible to elect to be treated as a corporation, that timely files \nForm 2553 and meets all the other tests listed below. If Form \n2553 isn’t timely filed, see Relief for Late Elections, later.\n2. It has no more than 100 shareholders. You can treat \nan individual and his or her spouse (and their estates) as one \nshareholder for this test. You can also treat all members of a \nfamily (as defined in section 1361(c)(1)(B)) and their estates \nas one shareholder for this test. For additional situations in \nwhich certain entities will be treated as members of a family, \nsee Regulations section 1.1361-1(e)(3)(ii). All others are \ntreated as separate shareholders. For details, see section \n1361(c)(1).\n3. Its only shareholders are individuals, estates, exempt \norganizations described in section 401(a) or 501(c)(3), or \ncertain trusts described in section 1361(c)(2)(A).\nFor information about the section 1361(d)(2) election to be \na qualified subchapter S trust (QSST), see the instructions \nfor Part III. For information about the section 1361(e)(3) \nelection to be an electing small business trust (ESBT), see \nRegulations section 1.1361-1(m). For guidance on how to \nconvert a QSST to an ESBT, see Regulations section \n1.1361-1(j)(12). If these elections weren’t timely made, see \nRev. Proc. 2013-30, 2013-36 I.R.B. 173, available at \nIRS.gov/irb/2013-36_IRB#RP-2013-30.\n4. It has no nonresident alien shareholders (other than as \npotential current beneficiaries of an ESBT).\n5. It has only one class of stock (disregarding differences \nin voting rights). Generally, a corporation is treated as having \nonly one class of stock if all outstanding shares of the \ncorporation's stock confer identical rights to distribution and \nliquidation proceeds. See Regulations section 1.1361-1(l) for \ndetails.\n6. It isn’t one of the following ineligible corporations.\na. A bank or thrift institution that uses the reserve method \nof accounting for bad debts under section 585.\nb. An insurance company subject to tax under \nsubchapter L of the Code.\nc. A domestic international sales corporation (DISC) or \nformer DISC.\n7. It has or will adopt or change to one of the following tax \nyears.\na. A tax year ending December 31.\nb. A natural business year.\nc. An ownership tax year.\nd. A tax year elected under section 444.\ne. A 52-53-week tax year ending with reference to a year \nlisted above.\nf.\nAny other tax year (including a 52-53-week tax year) \nfor which the corporation (entity) establishes a business \npurpose.\nFor details on making a section 444 election or requesting \na natural business, ownership, or other business purpose tax \nyear, see the instructions for Part II.\n8. Each shareholder consents as explained in the \ninstructions for column K.\nSee sections 1361, 1362, and 1378, and their related \nregulations for additional information on the above tests.\nA parent S corporation can elect to treat an eligible wholly \nowned subsidiary as a qualified subchapter S subsidiary. If \nthe election is made, the subsidiary's assets, liabilities, and \nitems of income, deduction, and credit generally are treated \nas those of the parent. For details, see Form 8869, Qualified \nSubchapter S Subsidiary Election.\nWhen To Make the Election\nComplete and file Form 2553:\n• No more than 2 months and 15 days after the beginning of \nthe tax year the election is to take effect, or\n• At any time during the tax year preceding the tax year it is \nto take effect.\nFor this purpose, the 2-month period begins on the day of \nthe month the tax year begins and ends with the close of the \nday before the numerically corresponding day of the second \ncalendar month following that month. If there is no \nAug 05, 2020\nCat. No. 49978N\n", "corresponding day, use the close of the last day of the \ncalendar month.\nExample 1. No prior tax year. A calendar year small \nbusiness corporation begins its first tax year on January 7. \nThe 2-month period ends March 6 and 15 days after that is \nMarch 21. To be an S corporation beginning with its first tax \nyear, the corporation must file Form 2553 during the period \nthat begins January 7 and ends March 21. Because the \ncorporation had no prior tax year, an election made before \nJanuary 7 won’t be valid.\nExample 2. Prior tax year. A calendar year small business \ncorporation has been filing Form 1120 as a C corporation but \nwishes to make an S election for its next tax year beginning \nJanuary 1. The 2-month period ends February 28 (29 in leap \nyears) and 15 days after that is March 15. To be an S \ncorporation beginning with its next tax year, the corporation \nmust file Form 2553 during the period that begins the first day \n(January 1) of its last year as a C corporation and ends \nMarch 15th of the year it wishes to be an S corporation. \nBecause the corporation had a prior tax year, it can make the \nelection at any time during that prior tax year.\nExample 3. Tax year less than 21/2 months. A calendar \nyear small business corporation begins its first tax year on \nNovember 8. The 2-month period ends January 7 and 15 \ndays after that is January 22. To be an S corporation \nbeginning with its short tax year, the corporation must file \nForm 2553 during the period that begins November 8 and \nends January 22. Because the corporation had no prior tax \nyear, an election made before November 8 won’t be valid.\nRelief for Late Elections\nThe following two sections discuss relief for late S \ncorporation elections and relief for late S corporation and \nentity classification elections for the same entity. For \nsupplemental procedural requirements when seeking relief \nfor multiple late elections, see Rev. Proc. 2013-30, section \n4.04.\nWhen filing Form 2553 for a late S corporation election, \nthe corporation (entity) must enter in the top margin of the \nfirst page of Form 2553 “FILED PURSUANT TO REV. PROC. \n2013-30.” Also, if the late election is made by attaching Form \n2553 to Form 1120-S, the corporation (entity) must enter in \nthe top margin of the first page of Form 1120-S “INCLUDES \nLATE ELECTION(S) FILED PURSUANT TO REV. PROC. \n2013-30.”\nThe election can be filed with the current Form 1120-S if \nall earlier Forms 1120-S have been filed. The election can be \nattached to the first Form 1120-S for the year including the \neffective date if filed simultaneously with any other delinquent \nForms 1120-S. Form 2553 can also be filed separately.\nRelief for a Late S Corporation Election Filed by \na Corporation\nA late election to be an S corporation generally is effective for \nthe tax year following the tax year beginning on the date \nentered on line E of Form 2553. However, relief for a late \nelection may be available if the corporation can show that the \nfailure to file on time was due to reasonable cause.\nTo request relief for a late election, a corporation that \nmeets the following requirements must explain the \nreasonable cause for failure to timely file the election and its \ndiligent actions to correct the mistake upon discovery. This \ninformation can be provided on line I of Form 2553 or on an \nattached statement.\n1. The corporation intended to be classified as an S \ncorporation as of the date entered on line E of Form 2553;\n2. The corporation fails to qualify as an S corporation \n(see Who May Elect, earlier) on the effective date entered on \nline E of Form 2553 solely because Form 2553 wasn’t filed \nby the due date (see When To Make the Election, earlier);\n3. The corporation has reasonable cause for its failure to \ntimely file Form 2553 and has acted diligently to correct the \nmistake upon discovery of its failure to timely file Form 2553;\n4. Form 2553 will be filed within 3 years and 75 days of \nthe date entered on line E of Form 2553; and\n5. A corporation that meets requirements (1) through (4) \nmust also be able to provide statements from all \nshareholders who were shareholders during the period \nbetween the date entered on line E of Form 2553 and the \ndate the completed Form 2553 is filed stating that they have \nreported their income on all affected returns consistent with \nthe S corporation election for the year the election should \nhave been made and all subsequent years. Completion of \nForm 2553, Part I, column K, Shareholder's Consent \nStatement (or similar document attached to Form 2553), will \nmeet this requirement; or\n6. A corporation that meets requirements (1) through (3) \nbut not requirement (4) can still request relief for a late \nelection on Form 2553 if the following statements are true.\na. The corporation and all its shareholders reported their \nincome consistent with S corporation status for the year the S \ncorporation election should have been made, and for every \nsubsequent tax year (if any);\nb. At least 6 months have elapsed since the date on \nwhich the corporation filed its tax return for the first year the \ncorporation intended to be an S corporation; and\nc. Neither the corporation nor any of its shareholders was \nnotified by the IRS of any problem regarding the S \ncorporation status within 6 months of the date on which the \nForm 1120-S for the first year was timely filed.\nTo request relief for a late election when the above \nrequirements aren’t met, the corporation generally must \nrequest a private letter ruling and pay a user fee in \naccordance with Rev. Proc. 2021-1, 2021-1 I.R.B. 1 (or its \nsuccessor).\nRelief for a Late S Corporation Election Filed By \nan Entity Eligible To Elect To Be Treated as a \nCorporation\nA late election to be an S corporation and a late entity \nclassification election for the same entity may be available if \nthe entity can show that the failure to file Form 2553 on time \nwas due to reasonable cause. Relief must be requested \nwithin 3 years and 75 days of the effective date entered on \nline E of Form 2553.\nTo request relief for a late election, an entity that meets \nthe following requirements must explain the reasonable \ncause for failure to timely file the election and its diligent \nactions to correct the mistake upon discovery. This \ninformation can be provided on line I of Form 2553 or on an \nattached statement.\n-2-\nInstructions for Form 2553 (December 2020)\n", "1. The entity is an eligible entity as defined in Regulations \nsection 301.7701-3(a) (see Purpose of Form in the Form \n8832 instructions).\n2. The entity intended to be classified as an S \ncorporation as of the date entered on line E of Form 2553.\n3. Form 2553 will be filed within 3 years and 75 days of \nthe date entered on line E of Form 2553.\n4. The entity failed to qualify as a corporation solely \nbecause Form 8832 wasn’t timely filed under Regulations \nsection 301.7701-3(c)(1)(i) (see When To File in the Form \n8832 instructions), or Form 8832 wasn’t deemed to have \nbeen filed under Regulations section 301.7701-3(c)(1)(v)(C) \n(see Who Must File in the Form 8832 instructions).\n5. The entity fails to qualify as an S corporation (see Who \nMay Elect, earlier) on the effective date entered on line E of \nForm 2553 because Form 2553 wasn’t filed by the due date \n(see When To Make the Election, earlier).\n6. The entity either:\na. Timely filed all Forms 1120-S consistent with its \nrequested classification as an S corporation, or\nb. Didn’t file Form 1120-S because the due date for the \nfirst year's Form 1120-S hasn’t passed.\n7. The entity has reasonable cause for its failure to timely \nfile Form 2553 and has acted diligently to correct the mistake \nupon discovery of its failure to timely file Form 2553.\n8. The S corporation can provide statements from all \nshareholders who were shareholders during the period \nbetween the date entered on line E of Form 2553 and the \ndate the completed Form 2553 is filed stating that they have \nreported their income on all affected returns consistent with \nthe S corporation election for the year the election should \nhave been made and all subsequent years. Completion of \nForm 2553, Part I, column K, Shareholder's Consent \nStatement (or similar document attached to Form 2553), will \nmeet this requirement.\nTo request relief for a late election when the above \nrequirements aren’t met, the entity generally must request a \nprivate letter ruling and pay a user fee in accordance with \nRev. Proc. 2021-1 (or its successor).\nWhere To File\nGenerally, send the original election (no photocopies) or fax it \nto the Internal Revenue Service Center listed below. If the \ncorporation (entity) files this election by fax, keep the original \nForm 2553 with the corporation's (entity’s) permanent \nrecords. However, certain late elections can be filed attached \nto Form 1120-S. See Relief for Late Elections, earlier.\nPrivate delivery services. You can use certain private \ndelivery services (PDS) designated by the IRS to file this \nelection. Go to IRS.gov/PDS for the current list of designated \nservices.\nThe PDS can tell you how to get written proof of the \nmailing date.\nFor the IRS mailing address to use if you’re using PDS, go \nto IRS.gov/PDSStreetAddresses.\nIf the corporation's (entity’s) \nprincipal business, office, or \nagency is located in:\nUse the following \naddress or fax number:\nConnecticut, Delaware, \nDistrict of Columbia, Georgia, \nIllinois, Indiana, Kentucky, \nMaine, Maryland, \nMassachusetts, Michigan, New \nHampshire, New Jersey, New \nYork, North Carolina, Ohio, \nPennsylvania, Rhode Island, \nSouth Carolina, Tennessee, \nVermont, Virginia, West Virginia, \nWisconsin\nDepartment of the Treasury\nInternal Revenue\nService Center\nKansas City, MO 64999\nFax: 855-887-7734\nAlabama, Alaska, Arizona, \nArkansas, California, Colorado, \nFlorida, Hawaii, Idaho, Iowa, \nKansas, Louisiana, Minnesota, \nMississippi, Missouri, Montana, \nNebraska, Nevada, New \nMexico, North Dakota, \nOklahoma, Oregon, South \nDakota, Texas, Utah, \nWashington, Wyoming\nDepartment of the Treasury\nInternal Revenue\nService Center\nOgden, UT 84201\nFax: 855-214-7520\nThe filing information shown above is subject to \nchange. For the latest information, go to IRS.gov/\nFiling/Where-To-File-Your-Taxes-for-Form-2553.\nAcceptance or Nonacceptance of \nElection\nThe service center will notify the corporation (entity) if its \nelection is accepted and when it will take effect. The \ncorporation (entity) will also be notified if its election isn’t \naccepted. The corporation (entity) should generally receive a \ndetermination on its election within 60 days after it has filed \nForm 2553. If box Q1 in Part II is checked, the corporation \n(entity) will receive a ruling letter from the IRS that either \napproves or denies the selected tax year. When box Q1 is \nchecked, it will generally take an additional 90 days for the \nForm 2553 to be accepted.\nCare should be exercised to ensure that the IRS receives \nthe election. If the corporation (entity) isn’t notified of \nacceptance or nonacceptance of its election within 2 months \nof the date of filing (date faxed or mailed), or within 5 months \nif box Q1 is checked, take follow-up action by calling \n1-800-829-4933.\nIf the IRS questions whether Form 2553 was filed, an \nacceptable proof of filing is:\n• A certified or registered mail receipt (timely postmarked) \nfrom the U.S. Postal Service, or its equivalent from a \ndesignated private delivery service (see Notice 2016-30, \n2016-18 I.R.B. 676, available at\nIRS.gov/irb/2016-18_IRB#NOT-2016-30 (or its successor));\n• Form 2553 with an accepted stamp;\n• Form 2553 with a stamped IRS received date; or\n• An IRS letter stating that Form 2553 has been accepted.\nCAUTION\n!\nInstructions for Form 2553 (December 2020)\n-3-\n", "Do not file Form 1120-S for any tax year before the \nyear the election takes effect. If the corporation \n(entity) is now required to file Form 1120, U.S. \nCorporation Income Tax Return, or any other applicable tax \nreturn, continue filing it until the election takes effect.\nEnd of Election\nOnce the election is made, it stays in effect until it is \nterminated or revoked. IRS consent generally is required for \nanother election by the corporation (or a successor \ncorporation) on Form 2553 for any tax year before the 5th tax \nyear after the first tax year in which the termination or \nrevocation took effect. See Regulations section 1.1362-5 for \ndetails.\nSpecific Instructions\nPart I\nName and Address\nEnter the corporation's (entity’s) true name as stated in the \ncorporate charter or other legal document creating it. If the \ncorporation's (entity’s) mailing address is the same as \nsomeone else's, such as a shareholder's, enter “C/O” and \nthis person's name following the name of the corporation \n(entity). Include the suite, room, or other unit number after the \nstreet address. If the Post Office doesn’t deliver to the street \naddress and the corporation (entity) has a P.O. box, show \nthe box number instead of the street address. If the \ncorporation (entity) changed its name or address after \napplying for its employer identification number, be sure to \ncheck the box in item D of Part I.\nItem A. Employer Identification Number (EIN)\nEnter the corporation's (entity’s) EIN. If the corporation \n(entity) doesn’t have an EIN, it must apply for one. An EIN \ncan be applied for in the following ways.\n• Online—Go to IRS.gov/EIN. The EIN is issued \nimmediately once the application information is validated.\n• By faxing or mailing Form SS-4, Application for Employer \nIdentification Number.\nIf the corporation (entity) hasn’t received its EIN by the \ntime the return is due, enter “Applied For” and the date the \nEIN was applied in the space for the EIN. For more details, \nsee the Instructions for Form SS-4.\nItem E. Effective Date of Election\nForm 2553 generally must be filed no later than 2 \nmonths and 15 days after the date entered for item \nE. For details and exceptions, see When To Make \nthe Election and Relief for Late Elections, earlier.\nA corporation (or entity eligible to elect to be treated as a \ncorporation) making the election effective for its first tax year \nin existence should enter the earliest of the following dates:\n• The date the corporation (entity) first had shareholders \n(owners),\n• The date the corporation (entity) first had assets, or\n• The date the corporation (entity) began doing business.\nCAUTION\n!\nTIP\nWhen the corporation (entity) is making the election \nfor its first tax year in existence, it will usually enter \nthe beginning date of a tax year that begins on a date \nother than January 1.\nA corporation (entity) not making the election for its first \ntax year in existence that is keeping its current tax year \nshould enter the beginning date of the first tax year for which \nit wants the election to be effective.\nA corporation (entity) not making the election for its first \ntax year in existence that is changing its tax year and wants \nto be an S corporation for the short tax year needed to switch \ntax years should enter the beginning date of the short tax \nyear. If the corporation (entity) doesn’t want to be an S \ncorporation for this short tax year, it should enter the \nbeginning date of the tax year following this short tax year \nand file Form 1128, Application To Adopt, Change, or Retain \na Tax Year. If this change qualifies as an automatic approval \nrequest (Form 1128, Part II), file Form 1128 as an attachment \nto Form 2553. If this change qualifies as a ruling request \n(Form 1128, Part III), file Form 1128 separately. If filing Form \n1128, enter “Form 1128” on the dotted line to the left of the \nentry space for item E.\nItem F\nCheck the box that corresponds with the S corporation's \nselected tax year. If box (2) or (4) is checked, provide the \nadditional information about the tax year, and complete Part \nII of the form.\nSignature\nForm 2553 must be signed and dated by the president, vice \npresident, treasurer, assistant treasurer, chief accounting \nofficer, or any other corporate officer (such as tax officer) \nauthorized to sign.\nIf Form 2553 isn’t signed, it won’t be considered timely \nfiled.\nColumn J\nEnter the name and address of each shareholder or former \nshareholder required to consent to the election. If stock of the \ncorporation is held by a nominee, guardian, custodian, or an \nagent, enter the name and address of the person for whom \nthe stock is held. If a single member limited liability company \n(LLC) owns stock in the corporation, and the LLC is treated \nas a disregarded entity for federal income tax purposes, \nenter the owner's name and address. The owner must be \neligible to be an S corporation shareholder.\nFor an election filed before the effective date entered for \nitem E, only shareholders who own stock on the day the \nelection is made need to consent to the election.\nFor an election filed on or after the effective date entered \nfor item E, all shareholders or former shareholders who \nowned stock at any time during the period beginning on the \neffective date entered for item E and ending on the day the \nelection is made must consent to the election.\nIf the corporation timely filed an election, but one or more \nshareholders didn’t timely file a consent, see Regulations \nsection 1.1362-6(b)(3)(iii). If the shareholder was a \ncommunity property spouse who was a shareholder solely \nbecause of a state community property law, see Rev. Proc. \n2004-35, 2004-23 I.R.B. 1029, available at IRS.gov/irb/\n2004-23_IRB#RP-2004-35.\nCAUTION\n!\n-4-\nInstructions for Form 2553 (December 2020)\n", "Column K. Shareholder's Consent Statement\nEach shareholder consents by signing and dating either in \ncolumn K or on a separate consent statement. The following \nspecial rules apply in determining who must sign.\n• If an individual and his or her spouse have a community \ninterest in the stock or in the income from it, both must \nconsent. For more information about community property, \nsee Pub. 555.\n• Each tenant in common, joint tenant, and tenant by the \nentirety must consent.\n• A minor's consent is made by the minor, legal \nrepresentative of the minor, or a natural or adoptive parent of \nthe minor if no legal representative has been appointed.\n• The consent of an estate is made by the executor or \nadministrator.\n• The consent of an electing small business trust (ESBT) is \nmade by the trustee and, if a grantor trust, the deemed \nowner. See Regulations section 1.1362-6(b)(2)(iv) for details.\n• If the stock is owned by a qualified subchapter S trust \n(QSST), the deemed owner of the trust must consent.\n• If the stock is owned by a trust (other than an ESBT or \nQSST), the person treated as the shareholder by section \n1361(c)(2)(B) must consent.\nContinuation sheet or separate consent statement. If \nyou need a continuation sheet or use a separate consent \nstatement, attach it to Form 2553. It must contain the name, \naddress, and EIN of the corporation (entity) and the \ninformation requested in columns J through N of Part I.\nColumn L\nEnter the number of shares of stock each shareholder owns \non the date the election is filed and the date(s) the stock was \nacquired. Enter -0- for any former shareholders listed in \ncolumn J. An entity without stock, such as a limited liability \ncompany (LLC), should enter the percentage of ownership \nand date(s) acquired.\nColumn M\nEnter the social security number of each individual listed in \ncolumn J. Enter the EIN of each estate, qualified trust, or \nexempt organization.\nColumn N\nEnter the month and day that each shareholder's tax year \nends. If a shareholder is changing his or her tax year, enter \nthe tax year the shareholder is changing to, and attach an \nexplanation indicating the present tax year and the basis for \nthe change (for example, an automatic revenue procedure or \na letter ruling request).\nPart II\nComplete Part II if you checked box (2) or (4) in Part I, item F.\nNote. Corporations can’t obtain automatic approval of a \nfiscal year under the natural business year (box P1) or \nownership tax year (box P2) provisions if they are under \nexamination, before an appeals (area) office, or before a \nfederal court without meeting certain conditions and \nattaching a statement to the application. For details, see \nsection 7.03 of Rev. Proc. 2006-46, 2006-45 I.R.B. 859, \navailable at IRS.gov/irb/2006-45_IRB#RP-2006-46.\nBox P1\nA corporation that doesn’t have a 47-month period of gross \nreceipts can’t automatically establish a natural business year.\nBox Q1\nFor examples of an acceptable business purpose for \nrequesting a fiscal tax year, see section 5.02 of Rev. Proc. \n2002-39, 2002-22 I.R.B. 1046, and Rev. Rul. 87-57, 1987-2 \nC.B. 117.\nAttach a statement showing the relevant facts and \ncircumstances to establish a business purpose for the \nrequested fiscal year. For details on what is sufficient to \nestablish a business purpose, see section 5.02 of Rev. Proc. \n2002-39.\nIf your business purpose is based on one of the natural \nbusiness year tests provided in section 5.03 of Rev. Proc. \n2002-39, identify which test you are using (the 25% gross \nreceipts, annual business cycle, or seasonal business test). \nFor the 25% gross receipts test, provide a schedule showing \nthe amount of gross receipts for each month for the most \nrecent 47 months. For either the annual business cycle or \nseasonal business test, provide the gross receipts from sales \nand services (and inventory costs, if applicable) for each \nmonth of the short period, if any, and the three immediately \npreceding tax years. If the corporation has been in existence \nfor less than three tax years, submit figures for the period of \nexistence.\nIf you check box Q1, you will be charged a user fee of \n$6,200 (subject to change by Rev. Proc. 2021-1 or its \nsuccessor). Don’t pay the fee when filing Form 2553. The \nservice center will send Form 2553 to the IRS in Washington, \nDC, who, in turn, will notify the corporation that the fee is due.\nBox Q2\nIf the corporation makes a back-up section 444 election for \nwhich it is qualified, then the section 444 election will take \neffect in the event the business purpose request isn’t \napproved. In some cases, the tax year requested under the \nback-up section 444 election may be different than the tax \nyear requested under business purpose. See Form 8716, \nElection To Have a Tax Year Other Than a Required Tax \nYear, for details on making a back-up section 444 election.\nBoxes Q3 and R2\nIf the corporation isn’t qualified to make the section 444 \nelection after making the item Q2 back-up section 444 \nelection or indicating its intention to make the election in item \nR1, and therefore it later files a calendar year return, it should \nenter “Section 444 Election Not Made” in the top left corner of \nthe first calendar year Form 1120-S it files.\nPart III\nUse Part III only if you make the election in Part I. \nForm 2553 can’t be filed with only Part III completed.\nIn Part III, the income beneficiary (or legal representative) \nof certain qualified subchapter S trusts (QSSTs) may make \nthe QSST election required by section 1361(d)(2). Part III \nmay be used to make the QSST election only if corporate \nstock has been transferred to the trust on or before the date \non which the corporation makes its election to be an S \ncorporation. However, a statement can be used instead of \nCAUTION\n!\nInstructions for Form 2553 (December 2020)\n-5-\n", "Part III to make the election. If there was an inadvertent \nfailure to timely file a QSST election, see the relief provisions \nunder Rev. Proc. 2013-30.\nThe deemed owner of the QSST must also consent to the \nS corporation election in column K of Form 2553.\nAdditional QSST election. If you are making more than \none QSST election, use additional copies of page 4 or use a \nseparate election statement, and attach it to Form 2553. It \nmust contain all information requested under Part III.\nPart IV\nThe representations listed in Part IV must be attached to a \nlate corporate classification election intended to be effective \non the same date that a late S corporation election was \nintended to be effective. For more information on making \nthese late elections, see Relief for a Late S Corporation \nElection Filed By an Entity Eligible To Elect To Be Treated as \na Corporation, earlier.\nPaperwork Reduction Act Notice. We ask for the information on this form to carry out the Internal Revenue laws of the \nUnited States. You are required to give us the information. We need it to ensure that you are complying with these laws and to \nallow us to figure and collect the right amount of tax.\nYou are not required to provide the information requested on a form that is subject to the Paperwork Reduction Act unless \nthe form displays a valid OMB control number. Books or records relating to a form or its instructions must be retained as long \nas their contents may become material in the administration of any Internal Revenue law. Generally, tax returns and return \ninformation are confidential, as required by section 6103.\nThe time needed to complete and file this form will vary depending on individual circumstances. The estimated burden for \nbusiness taxpayers filing this form is approved under OMB control number 1545-0123 and is included in the estimates shown \nin the instructions for their business income tax return. The estimated burden for all other taxpayers who file this form is shown \nbelow.\nRecordkeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n9 hr., 48 min.\nLearning about the law or the form . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n2 hr., 33 min.\nPreparing and sending the form to the IRS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .\n4 hr., 1 min.\nIf you have comments concerning the accuracy of these time estimates or suggestions for making this form simpler, we \nwould be happy to hear from you. You can send us comments from IRS.gov/FormComments. Or you can write to the Internal \nRevenue Service, Tax Forms and Publications Division, 1111 Constitution Ave. NW, IR-6526, Washington, DC 20224. Don’t \nsend the form to this office.\n-6-\nInstructions for Form 2553 (December 2020)\n" ]
p5468asp.pdf	1120 Publ 5468-A (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5468asp.pdf	[ "Publication 5468-A (sp) (11-2020) Catalog Number 75123W Department of the Treasury Internal Revenue Service www.irs.gov\nConozca al IRS, \nsu gente y los \nproblemas que \nafectan a los \ncontribuyentes\n“Un Vistazo de Cerca” es una nueva sección en el sitio web del IRS que cubrirá una variedad de temas \nactuales de interés para los contribuyentes y la comunidad tributaria. También proporcionará una visión \ndetallada de los temas claves que afectan tanto a las operaciones del IRS como a empleados, y temas que \ninvolucran a los contribuyentes y profesionales de impuestos. \nMire más de cerca\nConéctese con el IRS \n \nVerifique cuentas en \nIRS.gov/socialmedia\nUN \nVISTAZ DE \nCERCA\nVea aquí publicaciones anteriores y \nnuevas actualizaciones.\nIRS.gov/vistazodecerca\n" ]
i8869.pdf	1220 Inst 8869 (PDF)	https://www.irs.gov/pub/irs-pdf/i8869.pdf	[ "Instructions for Form 8869\n(Rev. December 2020)\nQualified Subchapter S Subsidiary Election\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue Code \nunless otherwise noted.\nFuture Developments\nFor the latest information about developments related to \nForm 8869 and its instructions, such as legislation \nenacted after they were published, go to IRS.gov/\nForm8869.\nGeneral Instructions\nPurpose of Form\nA parent S corporation uses Form 8869 to elect to treat \none or more of its eligible subsidiaries as a qualified \nsubchapter S subsidiary (QSub).\nThe QSub election results in a deemed liquidation of \nthe subsidiary into the parent. Following the deemed \nliquidation, for federal tax purposes, the QSub is not \ntreated as a separate corporation and all of the \nsubsidiary’s assets, liabilities, and items of income, \ndeduction, and credit are treated as those of the parent.\nBecause the liquidation is a deemed liquidation, \ndo not file Form 966, Corporate Dissolution or \nLiquidation. However, a final return for the \nsubsidiary may have to be filed if it was a separate \ncorporation prior to the date of the deemed liquidation. No \nfinal return is required if this election is being made \npursuant to a reorganization under section 368(a)(1)(F) \nand Rev. Rul. 2008-18. See Rev. Rul. 2008-18, 2008-13 \nI.R.B. 674, available at IRS.gov/irb/\n2008-13_IRB#RR-2008-18, for details.\nEligible Subsidiary\nAn eligible subsidiary is a domestic corporation whose \nstock is owned 100% by an S corporation and is not one \nof the following ineligible corporations.\n• A bank or thrift institution that uses the reserve method \nof accounting for bad debts under section 585.\n• An insurance company subject to tax under subchapter \nL of the Internal Revenue Code.\n• A domestic international sales corporation (DISC) or \nformer DISC.\nSee sections 1361(b)(3), 1362(f), and their related \nregulations for additional information.\nWhen To Make the Election\nThe parent S corporation can make the QSub election for \nan eligible corporation at any time during the tax year. \nHowever, the requested effective date of the QSub \nelection generally cannot be more than:\n• 12 months after the date the election is filed, or\n• 2 months and 15 days before the date the election is \nfiled.\nAn election filed more than 12 months before the \nrequested effective date will be made effective 12 months \nCAUTION\n!\nafter the date it is filed. An election filed more than 2 \nmonths and 15 days after the requested effective date \ngenerally is late and will be made effective 2 months and \n15 days before the date it is filed. However, an election \nfiled more than 2 months and 15 days after the requested \neffective date will be accepted as timely filed if the \ncorporation can show that the failure to file on time was \ndue to reasonable cause.\nTo request relief for a late election, the corporation \nmust generally request a private letter ruling and pay a \nuser fee in accordance with Rev. Proc. 2021-1, 2021-1 \nI.R.B. 1 (or its successor). However, relief from the ruling \nand user fee requirements is available. See Rev. Proc. \n2013-30, 2013-36 I.R.B. 173, for details.\nEven if a QSub election is made 12 months before \nor 2 months and 15 days after the effective date, a \nQSub election will be ineffective if made for a \ncorporation that was formerly eligible, but is ineligible at \nthe time the election is made. See Regulations section \n1.1361-3(a)(1).\nWhere To File\nFile Form 8869 with the service center where the \nsubsidiary filed its most recent return. However, if the \nparent S corporation forms a subsidiary, and makes a \nvalid election effective upon formation, submit Form 8869 \nto the service center where the parent S corporation filed \nits most recent return.\nAcceptance of Election\nThe service center will notify the corporation if the QSub \nelection is (a) accepted, and when it will take effect, or (b) \nnot accepted. The corporation may also receive an \nadministrative letter confirming the receipt of Form 8869.\nThe corporation should generally receive a \ndetermination on its election within 60 days after it has \nfiled Form 8869. However, if the corporation is not notified \nof acceptance or nonacceptance of its election within 2 \nmonths of the date of filing (date mailed), take follow-up \naction by calling 800-829-4933.\nIf the IRS questions whether Form 8869 was filed, an \nacceptable proof of filing is (a) a certified or registered \nmail receipt (timely postmarked) from the U.S. Postal \nService, or its equivalent from a designated private \ndelivery service (go to IRS.gov/PDS for the current list of \ndesignated services); (b) a Form 8869 with an accepted \nstamp; (c) a Form 8869 with a stamped IRS received \ndate; or (d) an IRS letter stating that Form 8869 has been \naccepted.\nEnd of Election\nOnce the QSub election is made, it remains in effect until \nit is terminated. If the election is terminated, IRS consent \ngenerally is required for another QSub election with \nregard to the former QSub (or its successor) for any tax \nCAUTION\n!\nDec 02, 2020\nCat. No. 74389E\n", "year before the fifth tax year after the first tax year in which \nthe termination took effect. See Regulations section \n1.1361-5 for details.\nSpecific Instructions\nAddress\nInclude the suite, room, or other unit number after the \nstreet address. If the post office does not deliver to the \nstreet address and the corporation has a P.O. box, show \nthe box number instead.\nIf the subsidiary has the same address as the parent S \ncorporation, enter “Same as parent” in Part II.\nAdditional Subsidiaries\nIf the QSub election is being made for more than one \nsubsidiary, attach a separate sheet for each subsidiary. \nUse the same size, format, and line numbers as in Part II \nof the printed form. Put the parent corporation’s name and \nemployer identification number at the top of each sheet.\nIf the QSub elections are being made effective on the \nsame date for a tiered group of subsidiaries, the parent S \ncorporation may specify the order of the deemed \nliquidations on an attachment. If no order is specified, the \ndeemed liquidations will be treated as occurring first for \nthe lowest tier subsidiary and proceeding successively \nupward. See Regulations section 1.1361-4(b)(2).\nA QSub election for a tiered group of subsidiaries \nmay, in certain circumstances, result in the \nrecognition of income. A primary example is \nexcess loss accounts (see Regulations section \n1.1502-19).\nReorganizations\nLine 14. This box should be checked “Yes” if this election \nis being made pursuant to a reorganization under section \n368(a)(1)(F) and Rev. Rul. 2008-18. This occurs when a \nnewly formed parent holding company holds the stock of \nthe subsidiary that was an S corporation immediately \nbefore the transaction and the transaction otherwise \nqualifies as a reorganization under section 368(a)(1)(F). \nNo Form 2553, Election by a Small Business Corporation, \nis required to be filed by the parent. See Rev. Rul. \n2008-18 for details.\nEmployer Identification Number (EIN)\nA QSub may not be required to have an EIN for federal tax \npurposes. If the QSub does not have an EIN, enter “N/A” \non line 8.\nHowever, if the QSub has previously filed a return, \nseparately or as part of a consolidated return, and used \nan EIN, enter that EIN on line 8 and (if applicable) the EIN \nof its common parent on line 16b. If this election is being \nmade pursuant to a reorganization under section 368(a)\n(1)(F) and Rev. Rul. 2008-18, the old S corporation for \nwhich this QSub election is being made will retain its EIN. \nThe newly formed parent must get a new EIN. See Rev. \nRul. 2008-18 for details.\nCAUTION\n!\nFailure to enter the subsidiary’s EIN may result in \nthe service center sending a notice of delinquent \nfiling to the QSub.\nIf the QSub wants its own EIN, but does not have one, \napply for an EIN in the following ways.\n• Online—Go to IRS.gov/EIN. The EIN is issued \nimmediately once the application information is validated.\n• By faxing or mailing Form SS-4, Application for \nEmployer Identification Number.\nIf the QSub has not received its EIN by the time the \nelection is made, write “Applied For” on line 8. See the \nInstructions for Form SS-4 for details.\nEffective Date of Election\nForm 8869 must generally be filed no earlier than \n12 months before or no later than 2 months and \n15 days after the effective date requested on \nline 11. For details and exceptions, see When To Make \nthe Election, earlier.\nA parent S corporation that forms a new subsidiary and \nwants the election effective upon formation should enter \nthe formation date. A parent corporation that wants to \nmake the election for an existing subsidiary should enter \nthe requested effective date. For details about the effect \nof a QSub election, see Regulations section 1.1361-4.\nSignature\nForm 8869 must be signed and dated by the president, \nvice president, treasurer, assistant treasurer, chief \naccounting officer, or any other corporate officer (such as \ntax officer) authorized to sign the parent’s S corporation \nreturn.\nPaperwork Reduction Act Notice. We ask for the \ninformation on this form to carry out the Internal Revenue \nlaws of the United States. You are required to give us the \ninformation. We need it to ensure that you are complying \nwith these laws.\nYou are not required to provide the information \nrequested on a form that is subject to the Paperwork \nReduction Act unless the form displays a valid OMB \ncontrol number. Books or records relating to a form or its \ninstructions must be retained as long as their contents \nmay become material in the administration of any Internal \nRevenue law. Generally, tax returns and return \ninformation are confidential, as required by section 6103.\nThe time needed to complete and file this form will vary \ndepending on individual circumstances. The estimated \nburden for business taxpayers filing this form is approved \nunder OMB control number 1545-0123 and is included in \nthe estimates shown in the instructions for their business \nincome tax return.\nIf you have comments concerning the accuracy of \nthese time estimates or suggestions for making this form \nsimpler, we would be happy to hear from you. You can \nsend us comments from IRS.gov/FormComments. Or you \ncan write to the Internal Revenue Service, Tax Forms and \nPublications Division, 1111 Constitution Ave. NW, \nIR-6526, Washington, DC 20224. Don't send the form to \nthis office.\nCAUTION\n!\nTIP\n-2-\nInstructions for Form 8869 (December 2020)\n" ]
p5468sp.pdf	1120 Publ 5468 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5468sp.pdf	[ "Publication 5468 (sp) (11-2020) Catalog Number 75116H Department of the Treasury Internal Revenue Service www.irs.gov\nConozca al IRS, \nsu gente y los \nproblemas que \nafectan a los \ncontribuyentes\n“Un Vistazo de Cerca” es una nueva sección en el sitio web del IRS que cubrirá una variedad de temas \nactuales de interés para los contribuyentes y la comunidad tributaria. También proporcionará una visión \ndetallada de los temas claves que afectan tanto a las operaciones del IRS como a empleados, y temas que \ninvolucran a los contribuyentes y profesionales de impuestos. \nMire más de cerca\nVea aquí publicaciones anteriores y \nnuevas actualizaciones.\nConéctese con el IRS \n \nVerifique cuentas en \nIRS.gov/socialmedia\nUN \nVISTAZO DE CERCA\nUN VISTAZO DE CERCA\nIRS.gov/vistazodecerca\n" ]
i1099h.pdf	1220 Inst 1099-H (PDF)	https://www.irs.gov/pub/irs-pdf/i1099h.pdf	[ "Instructions for Form 1099-H\n(Rev. December 2020)\nHealth Coverage Tax Credit (HCTC) Advance Payments\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue Code \nunless otherwise noted.\nFuture Developments\nFor the latest information about developments related to \nForm 1099-H and its instructions, such as legislation \nenacted after they were published, go to IRS.gov/\nForm1099H.\nReminders\nGeneral instructions. In addition to these specific \ninstructions, you should also use the current General \nInstructions for Certain Information Returns. Those \ngeneral instructions include information about the \nfollowing topics.\n• Backup withholding.\n• Electronic reporting.\n• Penalties.\n• Who must file.\n• When and where to file.\n• Taxpayer identification numbers (TINs).\n• Statements to recipients.\n• Corrected and void returns.\n• Other general topics.\nYou can get the general instructions from General \nInstructions for Certain Information Returns at IRS.gov/\n1099GeneralInstructions or go to IRS.gov/Form1099H.\nContinuous-use form and instructions. Form 1099-H \nand these instructions have been converted from an \nannual revision to continuous use. Both the form and \ninstructions will be updated as needed. For the most \nrecent version, go to IRS.gov/Form1099H.\nSpecific Instructions\nFile Form 1099-H if you received any advance payments \nduring the calendar year of qualified health insurance \npayments for the benefit of recipients of eligible trade \nadjustment assistance (TAA), Alternative TAA (ATAA), \nReemployment TAA (RTAA); or Pension Benefit Guaranty \nCorporation (PBGC) payees, and their qualifying family \nmembers. These individuals are referred to in these \ninstructions as recipients.\nWho Must File\nSection 6050T requires providers of qualified health \ninsurance coverage (defined in section 35(e)) that receive \nadvance payments of the HCTC from the Department of \nthe Treasury on behalf of eligible recipients (pursuant to \nsection 7527) to file Forms 1099-H to report those \nadvance payments and to furnish a statement reporting \nthat information to the recipient.\nHowever, Notice 2004-47, 2004-29 I.R.B. 48, available \nat IRS.gov/irb/2004-29_IRB#NOT-2004-47, provides that \nthe IRS HCTC Program (formerly the IRS HCTC \nTransaction Center), as an administrator of the HCTC, will \nfile the required returns and furnish statements to the \nrecipients unless you elect to file and furnish information \nreturns and statements on your own. Contact the HCTC \nProgram for this purpose by emailing the HCTC Program \nat [email protected]. Unless you notify the \nHCTC Program of your intent to file information returns \nand furnish statements, you will be considered to have \nelected to have the HCTC Program file Form 1099-H and \nfurnish statements to recipients in satisfying section \n6050T filing and furnishing requirements.\nHow To File\nFor filing with the IRS, see part E in the current General \nInstructions for Certain Information Returns and Pub. \n1220.\nStatements to Recipients\nIf you are required to file Form 1099-H, a statement must \nbe furnished to the recipient. The HCTC Program will \nfurnish a copy of Form 1099-H or an acceptable substitute \nstatement to each recipient on your behalf, unless you \nelect to file Form 1099-H and furnish the copy or \nsubstitute statement yourself. If you make this election, \nyou may fill out the form, found online at IRS.gov/\nForm1099H, and send Copy B to the recipient. See part J \nin the current General Instructions for Certain Information \nReturns.\nTruncating recipient‘s TIN on recipient statements. \nPursuant to Treasury Regulations section 301.6109-4, all \nfilers of this form may truncate a recipient’s TIN (social \nsecurity number (SSN), individual taxpayer identification \nnumber (ITIN), or adoption taxpayer identification number \n(ATIN)) on recipient statements. Truncation is not allowed \non any documents the filer files with the IRS. A filer’s TIN \nmay not be truncated on any form. See part J in the \ncurrent General Instructions for Certain Information \nReturns.\nExpired ITINs may continue to be used for \ninformation return purposes regardless of whether \nthey have expired for individual income tax return \nfiling purposes. See part J in the current General \nInstructions for Certain Information Returns.\nWaiver of penalties. Section 6724(a) authorizes the IRS \nto waive any penalties under sections 6721 and 6722 for \nfailure to comply with the reporting requirements of \nsection 6050T if such failures resulted from reasonable \ncause and not willful neglect. The HCTC Program will \nfurnish a copy of Form 1099-H or an acceptable substitute \nstatement to each recipient on your behalf, unless you \nelect to file Form 1099-H and furnish the copy or \nsubstitute statement yourself. The IRS will not assert the \npenalties imposed by sections 6721 and 6722 for \ninformation returns and statements required to be filed \nCAUTION\n!\nNov 19, 2020\nCat. No. 35080G\n", "and furnished under section 6050T against you if you \nallow the HCTC Program to file and furnish Forms \n1099-H. If you elect not to allow the HCTC Program to file \nand furnish Forms 1099-H, the general rules for seeking a \npenalty waiver under section 6724(a) apply. See \nRegulations section 301.6724-1. For more information on \npenalties, see part O in the current General Instructions \nfor Certain Information Returns.\nBox 1—Amount of HCTC Advance Payments\nEnter the total amount of advance payments of health \ninsurance premiums received on behalf of the recipient for \nthe period January 1 through December 31 of the current \nyear. The amount received for the current year cannot \nexceed 72.5% of the total health insurance premium for \nthe individual.\nBox 2—No. of Mos. HCTC Payments Received\nEnter the number of months payments were received on \nbehalf of the recipient. This number cannot be more than \n12.\nBoxes 3 Through 14—Amount of Advance \nPayment(s) Included in Box 1\nEnter the amount of the advance payment received for \neach month in the applicable box. You may receive these \npayments prior to the month for which they are paid. Be \nsure to enter the amounts in the correct box.\n-2-\nInstructions for Form 1099-H (Rev. 12-2020)\n" ]
p5468a.pdf	1120 Publ 5468-A (PDF)	https://www.irs.gov/pub/irs-pdf/p5468a.pdf	[ " \n \n \n \n \nFollow IRS \n \nA \nCL SER \nLOOK \nGet to know the IRS, \n \nits people and the \n \nissues that affect \n \ntaxpayers. \nCheck here for prior posts and new updates. \nwww.irs.gov/a-closer-look \n“A Closer Look” is a new area on the IRS website that will cover a variety of timely issues of \ninterest to taxpayers and the tax community. It will also provide a detailed look at key issues \naffecting everything from IRS operations and employees to issues involving taxpayers and \ntax professionals. \nTake a closer look. \nVerify accounts at \nIRS.gov/socialmedia \nPublication 5468-A (11-2020) Catalog Number 75121A Department of the Treasury Internal Revenue Service www.irs.gov \n" ]
f5471sp.pdf	1220 Form 5471 (Schedule P) (PDF)	https://www.irs.gov/pub/irs-pdf/f5471sp.pdf	[ "SCHEDULE P \n(Form 5471)\n(Rev. December 2020)\nDepartment of the Treasury \nInternal Revenue Service\nPreviously Taxed Earnings and Profits of U.S. Shareholder \nof Certain Foreign Corporations\n▶ Attach to Form 5471. \n▶ Go to www.irs.gov/Form5471 for instructions and the latest information.\nOMB No. 1545-0123\nName of person filing Form 5471\nIdentifying number\nName of U.S. shareholder\nIdentifying number\nName of foreign corporation\nEIN (if any)\nReference ID number (see instructions)\na\nSeparate Category (Enter code—see instructions.) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nb\nIf code 901j is entered on line a, enter the country code for the sanctioned country (see instructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nPart I\nPreviously Taxed E&P in Functional Currency (see instructions)\n(a) \nReclassified section \n965(a) PTEP\n(b) \nReclassified section \n965(b) PTEP\n(c) \nGeneral section \n959(c)(1) PTEP\n1a\nBalance at beginning of year (see instructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nb\nBeginning balance adjustments (attach statement) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nc\nAdjusted beginning balance (combine lines 1a and 1b) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2\nReduction for taxes unsuspended under anti-splitter rules \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n3\nPreviously taxed E&P attributable to distributions of previously taxed E&P from lower-tier foreign corporation \n4\nPreviously taxed E&P carried over in nonrecognition transaction \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n5\nOther adjustments (attach statement) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n6\nTotal previously taxed E&P (combine lines 1c through 5) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n7\nAmounts reclassified to section 959(c)(2) E&P from section 959(c)(3) E&P \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n8 \nActual distributions of previously taxed E&P .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n9\nAmounts reclassified to section 959(c)(1) E&P from section 959(c)(2) E&P \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n10 \n \nAmounts included as earnings invested in U.S. property and reclassified to section 959(c)(1) E&P (see \ninstructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n11\nOther adjustments (attach statement) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n12\nBalance at beginning of next year (combine lines 6 through 11) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nFor Paperwork Reduction Act Notice, see instructions.\nCat. No. 49203F\nSchedule P (Form 5471) (Rev. 12-2020)\n", "Schedule P (Form 5471) (Rev. 12-2020)\nPage 2\nPart I\nPreviously Taxed E&P in Functional Currency (see instructions) (continued)\n(d) \nReclassified section \n951A PTEP\n(e) \nReclassified section \n245A(d) PTEP\n(f) \nSection 965(a) PTEP\n(g) \nSection 965(b) PTEP\n(h) \nSection 951A \nPTEP\n(i) \nSection 245A(d) \nPTEP\n(j) \nSection 951(a)(1)(A) \nPTEP\n(k) \nTotal\n1a\nb\nc\n2\n3\n4\n5\n6\n7\n8\n9\n10 \n11\n12 \nSchedule P (Form 5471) (Rev. 12-2020)\n", "Schedule P (Form 5471) (Rev. 12-2020)\nPage 3\nPart II\nPreviously Taxed E&P in U.S. Dollars \n(a) \nReclassified section \n965(a) PTEP\n(b) \nReclassified section \n965(b) PTEP\n(c) \nGeneral section \n959(c)(1) PTEP\n1a\nBalance at beginning of year (see instructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nb\nBeginning balance adjustments (attach statement) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nc\nAdjusted beginning balance (combine lines 1a and 1b) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2\nReduction for taxes unsuspended under anti-splitter rules \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n3\nPreviously taxed E&P attributable to distributions of previously taxed E&P from lower-tier foreign \ncorporation .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4\nPreviously taxed E&P carried over in nonrecognition transaction \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n5\nOther adjustments (attach statement) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n6\nTotal previously taxed E&P (combine lines 1c through 5) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n7\nAmounts reclassified to section 959(c)(2) E&P from section 959(c)(3) E&P \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n8 \nActual distributions of previously taxed E&P .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n9\nAmounts reclassified to section 959(c)(1) E&P from section 959(c)(2) E&P \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n10\nAmounts included as earnings invested in U.S. property and reclassified to section 959(c)(1) E&P (see \ninstructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n11\nOther adjustments (attach statement) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n12\nBalance at beginning of next year (combine lines 6 through 11) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nSchedule P (Form 5471) (Rev. 12-2020)\n", "Schedule P (Form 5471) (Rev. 12-2020)\nPage 4\nPart II\nPreviously Taxed E&P in U.S. Dollars (continued)\n(d) \nReclassified section \n951A PTEP\n(e) \nReclassified section \n245A(d) PTEP\n(f) \nSection 965(a) PTEP\n(g) \nSection 965(b) PTEP\n(h) \nSection 951A \nPTEP\n(i) \nSection 245A(d) \nPTEP\n(j) \nSection 951(a)(1)(A) \nPTEP\n(k) \nTotal\n1a\nb\nc\n2\n3\n4\n5\n6\n7\n8\n9\n10 \n11\n12 \nSchedule P (Form 5471) (Rev. 12-2020)\n" ]
f970.pdf	1120 Form 970 (PDF)	https://www.irs.gov/pub/irs-pdf/f970.pdf	[ "Form 970\n(Rev. November 2020) \nDepartment of the Treasury \nInternal Revenue Service \nApplication To Use LIFO Inventory Method\n▶ Attach to your tax return. \n▶ Go to www.irs.gov/Form970 for the latest information. \nOMB No. 1545-0042 \nAttachment \nSequence No. 122\nName of filer (name of parent corporation if a consolidated group) (see instructions) \nFiler’s identification number (see instructions) \nName of applicant(s) (if different from filer) and identification number(s) \nPart I \nStatement of Election Under Section 472 \nYes No \n1 \nThe applicant elects to use the LIFO inventory method for the tax year ending (enter month, day, year) ▶ \n for the following goods (enter here): \nSee instructions and attach a statement if necessary. \n2 \n \nIn an attached statement, identify and describe the inventory method(s) used by the applicant in the prior tax year \nfor the goods covered by this election. \n3 \na Is the applicant already using the LIFO inventory method for any other goods? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nb If “Yes” to line 3a, attach a statement identifying and describing the goods and the LIFO methods used. \n4 \na Has the applicant ever used the LIFO inventory method for the goods covered by this election? .\n.\n.\n.\n.\n.\nb \n \nIf “Yes” to line 4a, attach a statement listing the tax years for which the LIFO inventory method was used and \nexplaining why the LIFO inventory method was discontinued. \n5 \nThe applicant will not use the LIFO inventory method to account for the following goods (enter here): ▶\nAttach a statement if necessary. \nPart II \nLIFO Inventory Requirements \nYes No \n6 \n \na \n \nDid the applicant value the closing inventories of goods covered by this election at cost for the tax year \nimmediately preceding the tax year specified on line 1? \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nb \n \nIf “No” to line 6a, did the applicant value the beginning inventories of goods covered by this election at cost for \nthe tax year specified on line 1 as required by section 472(d)? \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nIf “No” to line 6b, attach an explanation. \nc If “Yes” to line 6b, will the applicant account for the adjustment required by section 472(d) over a 3-year period? \nIf “No” to line 6c, attach an explanation. \n7 \n \n \na \n \n \nWhen determining the beginning inventories of goods covered by this election, did the applicant treat those goods \nas being acquired for a unit cost that is equal to the total cost of those goods divided by the total number of units \non hand? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. \nb If “No” to line 7a, attach an explanation. \n8 \n \n \na \n \n \nDid the applicant (or any member of the same group of financially related corporations as defined in section\n472(g)) issue credit statements or reports to shareholders, partners, other proprietors, or beneficiaries covering the\ntax year specified on line 1? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nb \n \nIf “Yes” to line 8a, attach a statement describing the recipient(s), the date(s) of issuance, and the inventory \nmethod(s) used to determine income, profit, or loss in those statements. \n9 \na Will the applicant determine beginning and ending inventories at cost regardless of market value?\n.\n.\n.\n.\n. \nb If “No” to line 9a, attach an explanation. \n10 \n \n \n \na \n \n \n \nAs a condition of adopting the LIFO inventory method, Regulations section 1.472-4 requires a taxpayer to agree \nto make any adjustments incident to the change to, the change from, or the use of, the LIFO inventory method \nthat, upon the examination of the taxpayer’s income tax return, the IRS determines are necessary to clearly reflect \nincome. Does the applicant agree to this condition? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nb If “No” to line 10a, the applicant is not eligible to use the LIFO inventory method and does not need to file Form 970. \nPart III \nSpecific Goods (Unit) Method \n11 \n \n \n \nUnder Regulations section 1.472-1, the types of goods in the opening inventory must be compared with similar types of goods \nin the closing inventories. Attach a list of the types or categories of goods that will be compared, describe the goods that will \nbe included in each type or category, and identify the unit of measure (pounds, barrels, feet, etc.) used for each type or \ncategory. \nFor Paperwork Reduction Act Notice, see the instructions. \nCat. No. 17057T \nForm 970 (Rev. 11-2020) \n", "Form 970 (Rev. 11-2020) \nPage 2 \nPart III \nSpecific Goods (Unit) Method (continued) \n12 \n \nCheck the box corresponding to the method that the applicant will use to determine the cost of the goods in the closing \ninventories in excess of the cost of the goods in the opening inventories. See instructions.\nActual cost of goods most recently purchased or produced \nAverage cost of goods purchased or produced during the tax year \nActual cost of goods purchased or produced in the order of acquisition \nOther (attach explanation) \nPart IV \nDollar-Value Method \n13 \nAttach a statement describing the applicant’s method of defining “items.” \n14 \na Did the applicant acquire any of the goods covered by this election at below-market prices? \n.\n.\n.\n.\n.\nYes\nNo\nb \n \n \nIf “Yes” to line 14a, attach a statement explaining whether the applicant did, or will, account for the goods purchased at \nbelow-market prices and similar goods produced or acquired at market prices as separate items. If the applicant did, or will, \naccount for both types of goods as the same item, explain and justify. \n15 \n \nAttach a statement describing the method of pooling the applicant will use for the goods covered by this election. If the \napplicant will use more than one dollar-value pool, list and describe the contents of each dollar-value pool. See instructions. \n16 \n \nIdentify or describe the method the applicant will use to compute the LIFO value of each dollar-value pool containing goods \ncovered by this election (for example, double-extension method, link-chain method, or index method). \nIf the applicant’s method is neither the double-extension method nor the Inventory Price Index Computation method, attach a \nstatement describing the method in detail and justifying the applicant’s use of the selected method. See instructions. \n17 \n \nCheck the box corresponding to the method the applicant will use to determine the current-year cost of goods in the closing \ninventories and to value the LIFO increments of the dollar-value pool(s). See instructions. \nActual cost of goods most recently purchased or produced \nAverage cost of goods purchased or produced during the tax year \nActual cost of goods purchased or produced in the order of acquisition \nOther (attach explanation) \nPart V \nInventory Price Index Computation (IPIC) Method \n18 \n \nCheck the box corresponding to the method the applicant will use to compute the LIFO value of each dollar-value pool \ncontaining goods covered by this election. See instructions. \nDouble-extension IPIC method \nLink-chain IPIC method \n19 \n \nCheck the box corresponding to the table from which the applicant will select Bureau of Labor Statistics (BLS) price indexes. \nSee instructions. \nTable 3 of the Consumer Price Index (CPI) Report \nTable 6 of the Producer Price Index (PPI) Detailed Report \nOther table of the PPI Detailed Report \nIf the applicant will use “Other table of the PPI Detailed Report,” attach a statement explaining why the other table is more \nappropriate than Table 6. \n20 \nWill the applicant use the 10 percent method? See instructions .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nYes\nNo\n21 \n \nIf the applicant elects to use a representative month for selecting BLS price indexes from the applicable report, enter the\nrepresentative month elected for each dollar-value pool. \nSee instructions and attach a statement if necessary. \nPart VI \nOther Information \n22 \n \nAttach a statement describing the applicant’s method of determining the cost of inventory items (for example, standard cost \nmethod, actual invoice cost, joint product cost method, or retail inventory method). \n23 \n \nDid the applicant receive IRS consent to change the method of valuing inventories for the tax year specified \non line 1? See instructions .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. \nYes\nNo\nForm 970 (Rev. 11-2020) \n", "Form 970 (Rev. 11-2020) \nPage 3 \nGeneral Instructions \nSection references are to the Internal Revenue Code unless \notherwise noted. \nFuture Developments \nFor the latest information about developments related to Form \n970 and its instructions, such as legislation enacted after they \nwere published, go to www.irs.gov/Form970.\nPurpose of Form \nForm 970 is filed with your income tax return to elect to use the \nlast-in, first-out (LIFO) inventory method described in section \n472. If you prefer, you can file an election statement that gives \nthe same information requested on Form 970. \nHow To Use Form 970 \nYou must complete Parts I, II, and VI. In addition, complete \nParts III, IV, and V, as applicable. \nWhen To File \nFile Form 970 (or a similar statement) with your tax return for \nthe first tax year you intend to use the LIFO method. \nIf you filed your return for the tax year in which you wish to \nuse the LIFO inventory method described in section 472 \nwithout making the election, you can make the election by filing \nan amended return within 12 months of the date you filed your \noriginal return. Attach Form 970 (or similar statement) to the \namended return and write “Filed pursuant to section \n301.9100-2” at the top of Form 970. File the amended return at \nthe same address the original return was filed. \nChange From LIFO Method \nOnce you adopt the LIFO method, it is irrevocable unless the \nIRS allows you to change to another method. To request \napproval to change from the LIFO inventory method, you can \nuse the automatic change procedures or the non-automatic \nchange procedures. For details, see Form 3115, Application for \nChange in Accounting Method. Also see the Instructions for \nForm 3115.\nLIFO Recapture Amount \nA C corporation must include in gross income a LIFO recapture \namount (defined below) if it: \n1. Used the LIFO method for its last tax year before the first \ntax year for which an election to be taxed as an S corporation \nbecomes effective, or \n2. Transferred LIFO inventory assets to an S corporation in a \nnonrecognition transaction in which those assets constitute \ntransferred basis property. \nThe LIFO recapture amount is the amount by which the C \ncorporation’s inventory amount of the inventory assets using the \nfirst-in, first-out (FIFO) method exceeds the inventory amount of \nsuch assets under the LIFO method at the close of the C \ncorporation’s last tax year as a C corporation (or for the year of \nthe transfer, if (2) above applies). \nFor additional information on LIFO recapture, see \nRegulations section 1.1363-2 and Rev. Proc. 94-61, 1994-2 \nC.B. 775. Also see the Instructions for Form 1120 and the \nInstructions for Form 1120-S. \nSpecific Instructions \nName and Identification Number \nEnter the name of the filer on the first line of page 1 of Form \n970. In general, the filer of the Form 970 is the applicant. \nHowever, if Form 970 is filed on behalf of the applicant, enter \nthe filer’s name and identification number on the first line of \nForm 970 and enter the applicant’s name and identification \nnumber on the second line. An individual’s identifying number is \nhis or her social security number. For all others, it is the entity’s \nemployer identification number. \nPart I—Statement of Election Under Section \n472 \nLine 1. Enter the tax year the LIFO inventory method will first \nbe used and list the inventory items for which you will use this \nmethod. Include only inventory items that are not already \ncovered under a previous LIFO election. Attach a detailed \nanalysis of all of your inventories as of the beginning and end of \nthe first tax year the LIFO method will be used and the \nbeginning inventory of the preceding tax year. Also, include the \nending inventory reported on your tax return for the preceding \ntax year. See Regulations sections 1.472-2 and 1.472-3 for \nmore details on preparing this analysis. \nPart III—Specific Goods (Unit) Method \nLine 12. See Regulations section 1.472-2 for more information. \nPart IV—Dollar-Value Method \nLine 15. Provide sufficient information to justify the pooling \nmethod you are using. Retailers, wholesalers, jobbers, and \ndistributors are required to pool their goods by major lines, \ntypes, or classes, as authorized under Regulations section \n1.472-8(c). Manufacturers or processors can use the natural \nbusiness unit pooling method, as authorized by Regulations \nsection 1.472-8(b)(1), or can establish multiple pools of similar \nitems in lieu of natural business unit pools, under Regulations \nsection 1.472-8(b)(3)(i). Multiple pools include raw materials \ncontent pools authorized by Regulations section \n1.472-8(b)(3)(ii). \nEligible small businesses can establish pools under the \nsimplified dollar-value LIFO method (discussed below). \nManufacturers or processors using the inventory price index \ncomputation (IPIC) method can establish pools based on the \ncommodity codes in Table 6 of the Producer Price Index (PPI) \nDetailed Report. A retailer using the IPIC method can establish \npools based on either the general expenditure categories in \nTable 3 of the Consumer Price Index (CPI) Report or on the \ncommodity codes in Table 6 of the PPI Detailed Report. A \nwholesaler, jobber, or distributor using the IPIC method can \nestablish pools based on the commodity codes in Table 6 of the \nPPI Report. The PPI and CPI Reports are published monthly by \nthe U.S. Bureau of Labor Statistics (BLS). Under the IPIC \nmethod, you can also combine pools under special 5% rules. \nSee Regulations sections 1.472-8(b)(4) and 1.472-8(c)(2) for \nmore information. \nDescribe any other method of pooling used. \nSimplified dollar-value LIFO method. An eligible small \nbusiness can elect to use the simplified dollar-value LIFO \nmethod. See sections 474(c) and 448(c)(3). If you are a member \nof a controlled group, the gross receipts of the group are used \nto determine if you qualify. This method requires that you \n", "Form 970 (Rev. 11-2020) \nPage 4 \nmaintain a separate inventory pool for items in each major \ncategory in the applicable government price index, and that you \nmake adjustments to each separate pool based on changes \nfrom the preceding tax year in the component of such index for \nthe major category. You do not need IRS consent to elect these \nprovisions. The election is in effect for the first year the election \nis made and for each succeeding year you qualify as an eligible \nsmall business. The election can be revoked only with IRS \nconsent. \nThe simplified dollar-value method requires that general \ncategories of inventory pools be established. The general \ncategories are based on categories of inventory items \ncontained in the PPI Detailed Report or the CPI Report. See \nsection 474 and Regulations section 1.472-8 for more details. \nLine 16. Generally, you can only use the double-extension \nmethod or the inventory price index computation method. See \nRegulations sections 1.472-8(e)(2) and 1.472-8(e)(3) for a \ndescription of these methods. However, if you use the link-\nchain, index, or “other” method, attach a detailed statement \nexplaining how the method is justified under Regulations section \n1.472-8(e)(1). In addition, if you use a link-chain method, your \nstatement should explain why the nature of the pool makes the \ndouble-extension or index method impractical or unsuitable. \nNew Vehicle Alternative LIFO Inventory Method. \nAutomobile dealers engaged in the trade or business of retail \nsales of new automobiles or new light-duty trucks can adopt or \nuse the New Vehicle Alternative LIFO Inventory Method under \nRev. Proc. 97-36, 1997-2 C.B. 450, as modified by Rev. Proc. \n2008-23, 2008-12 I.R.B. 664, or any succesor. A new \nautomobile dealer who previously elected this method under \nRev. Proc. 92-79, 1992-2 C.B. 457 is not required to change its \nmethod of accounting to comply with Rev. Proc. 97-36. For \ninformation on accounting method changes to this method, see \nsection 23.03 of Rev. Proc. 2019-43, 2019-48 I.R.B. 1107, or \nany successor. \nUsed Vehicle Alternative LIFO Inventory Method. \nAutomobile dealers engaged in the trade or business of retail \nsales of used automobiles or used light-duty trucks can adopt \nor use the Used Vehicle Alternative LIFO Inventory Method as \ndescribed in Rev. Proc. 2001-23, 2001-10 I.R.B. 784, as \nmodified by Announcement 2004-16, 2004-1 I.R.B. 668, and \nRev. Proc. 2008-23, or its successor. For information on \naccounting method changes to this method, see section 23.04 \nof Rev. Proc. 2019-43, or any successor, and change number \n59 in the List of DCNs in the Instructions for Form 3115. \nLine 17. See Regulations section 1.472-8(e)(2) for more \ninformation. \nPart V—Inventory Price Index Computation \n(IPIC) Method \nLine 18. See Regulations section 1.472-8(e)(3)(iii)(E) for a \ndescription of the double-extension and link-chain IPIC \nmethods, including examples. The use of either of these IPIC \nmethods is a method of accounting. For information on \naccounting method changes to or within an IPIC method, see \nchange numbers 61 and 62 in the List of DCNs in the \nInstructions for Form 3115. \nLine 19. Manufacturers, processors, wholesalers, jobbers, and \ndistributors must select BLS price indexes from Table 6 of the \nPPI Detailed Report, unless the taxpayer can demonstrate that \nselecting BLS price indexes from another table of the PPI \nDetailed Report is more appropriate. Retailers can select BLS \nprice indexes from either Table 3 of the CPI Report or from \nTable 6 (or another more appropriate table) of the PPI Detailed \nReport. \nLine 20. See Regulations section 1.472-8(e)(3)(iii)(C)(2) for a \ndescription of the 10 percent method. \nLine 21. See Regulations section 1.472-8(e)(3)(iii)(B)(3) before \ncompleting line 21. \nPart VI—Other Information \nLine 23. If you filed Form 3115 and received IRS consent to \nchange your method of valuing inventories for the tax year \nspecified on line 1, do not attach a copy of the approval letter \n(consent agreement). Retain a copy of the letter for your \nrecords. \nPrivacy Act and Paperwork Reduction Act Notice. We ask for \nthe information on this form to carry out the Internal Revenue \nlaws of the United States. You are required to give us the \ninformation. We need it to ensure that you are complying with \nthese laws and to allow us to figure and collect the right amount \nof tax. Subtitle B and section 6109, and the regulations require \nyou to provide this information.\nYou are not required to provide the information requested on \na form that is subject to the Paperwork Reduction Act unless \nthe form displays a valid OMB control number. Books or \nrecords relating to a form or its instructions must be retained as \nlong as their contents may become material in the \nadministration of any Internal Revenue law. Generally, tax \nreturns and return information are confidential, as required by \nsection 6103. However, section 6103 allows or requires the \nInternal Revenue Service to disclose information from this form \nin certain circumstances. For example, we may disclose \ninformation to the Department of Justice for civil or criminal \nlitigation, and to cities, states, the District of Columbia, and U.S. \ncommonwealths or possessions for use in administering their \ntax laws. We may also disclose this information to other \ncountries under a tax treaty, to federal and state agencies to \nenforce federal nontax criminal laws, or to federal law \nenforcement and intelligence agencies to combat terrorism. \nFailure to provide this information, or providing false \ninformation, may subject you to penalties. \nThe time needed to complete and file this form and related \nschedules will vary depending on individual circumstances. The \nestimated burden for individual taxpayers filing this form is \napproved under OMB control number 1545-0074; the estimated \nburden for business taxpayers filing this form is approved under \nOMB control number 1545-0123 and is included in the \nestimates shown in the instructions for their individual and \nbusiness income tax return. The estimated burden for all other \ntaxpayers who file this form is shown below. \nRecordkeeping \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n 7 hrs., 53 min. \nLearning about the law or the form .\n.\n.\n.\n. 4 hrs., 3 min.\nPreparing the form \n.\n.\n.\n.\n.\n.\n.\n.\n.\n. 8 hrs., 5 min. \nSending the form to the IRS .\n.\n.\n.\n.\n.\n.\n 1 hr., 4 min. \nIf you have comments concerning the accuracy of these time \nestimates or suggestions for making this form and related \nschedules simpler, we would be happy to hear from you. See \nthe instructions for the tax return with which this form is filed. \n" ]
p5468.pdf	1120 Publ 5468 (PDF)	https://www.irs.gov/pub/irs-pdf/p5468.pdf	[ " \n \n \n \n \n \n \nGet to know the IRS, \nits people and the \nissues that affect \ntaxpayers. \nCheck here for prior posts and new updates. \nwww.irs.gov/a-closer-look \nA \nCL SER \nLOOK \n“A Closer Look” is a new area on the IRS website that will cover a variety of timely issues of \ninterest to taxpayers and the tax community. It will also provide a detailed look at key issues \naffecting everything from IRS operations and employees to issues involving taxpayers and \ntax professionals. \nTake a closer look. \nFollow IRS \n \nVerify accounts at \nIRS.gov/socialmedia \nPublication 5468 (11-2020) Catalog Number 75115W Department of the Treasury Internal Revenue Service www.irs.gov \n" ]
f943a.pdf	1220 Form 943-A (PDF)	https://www.irs.gov/pub/irs-pdf/f943a.pdf	[ "Form 943-A\n(Rev. December 2020)\nAgricultural Employer’s Record of \nFederal Tax Liability\nDepartment of the Treasury \nInternal Revenue Service \n▶ Go to www.irs.gov/Form943A for instructions and the latest information.\n▶ File with Form 943 or Form 943-X.\nOMB No. 1545-0035 \nCalendar Year \nName (as shown on Form 943) \nEmployer identification number (EIN) \nYou must complete this form if you’re a semiweekly schedule depositor or became one because your accumulated tax liability during \nany month was $100,000 or more. Show tax liability here, not deposits. (The IRS gets deposit data from electronic funds transfers.) \nDon’t change your current year tax liability by adjustments reported on any Forms 943-X. \nJanuary Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nA Total liability for month ▶\nFebruary Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\nB Total liability for month ▶\nMarch Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nC Total liability for month ▶\nApril Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\nD Total liability for month ▶\nMay Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nE Total liability for month ▶\nJune Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\nF Total liability for month ▶\nFor Privacy Act and Paperwork Reduction Act Notice, see the separate instructions. \nCat. No. 17030C \nForm 943-A (Rev. 12-2020) \n", "Form 943-A (Rev. 12-2020) \nPage 2 \nJuly Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nG Total liability for month ▶\nAugust Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nH Total liability for month ▶\nSeptember Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\nI Total liability for month ▶\nOctober Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nJ Total liability for month ▶\nNovember Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\nK Total liability for month ▶\nDecember Tax Liability\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15\n16\n17\n18\n19\n20\n21\n22\n23\n24\n25\n26\n27\n28\n29\n30\n31\nL Total liability for month ▶\nM Total tax liability for year (add lines A through L). This must equal line 13 on Form 943\n.\n.\n. ▶\nForm 943-A (Rev. 12-2020) \n" ]
f8923.pdf	1120 Form 8923 (PDF)	https://www.irs.gov/pub/irs-pdf/f8923.pdf	[ "Form 8923\n(Rev. November 2020)\nDepartment of the Treasury \nInternal Revenue Service \nMine Rescue Team Training Credit\n▶ Attach to your tax return. \n▶ Go to www.irs.gov/Form8923 for the latest information. \nOMB No. 1545-0123\nName(s) shown on return\nIdentifying number\n1 \nTotal training program costs of qualified mine rescue team employees paid or incurred during the tax \nyear (up to $50,000 per qualified employee).\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n1 \n2 \nMultiply line 1 by 20% (0.20). See instructions for the adjustment you must make .\n.\n.\n.\n.\n.\n.\n2 \n3 \nMine rescue team training credit from partnerships and S corporations (see instructions) .\n.\n.\n.\n.\n3 \n4 \nAdd lines 2 and 3. Partnerships and S corporations, report this amount on Schedule K. All others, \nreport this amount on Form 3800, Part III, line 1u .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4 \nFor Paperwork Reduction Act Notice, see instructions.\nCat. No. 37735E\nForm 8923 (Rev. 11-2020)\n", "Form 8923 (Rev. 11-2020)\nPage 2 \nGeneral Instructions\nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nFor the latest information about developments related to Form \n8923 and its instructions, such as legislation enacted after they \nwere published, go to www.irs.gov/Form8923.\nWhat’s New\nThe mine rescue team training credit is extended for qualified \nmine rescue team training costs paid or incurred for tax years \nbeginning after 2017 and before 2021.\nPurpose of Form\nTaxpayers who employ individuals as miners in U.S. \nunderground mines use Form 8923 to claim the mine rescue \nteam training credit. This credit applies to training program \ncosts paid or incurred for qualified mine rescue team \nemployees. This credit expired for tax years beginning after \n2020. To find out if the mine rescue team training credit is \nextended beyond 2020, go to www.irs.gov/Form8923.\nDefinitions\nTraining program costs. Taxpayers who employ individuals as \nminers in U.S. underground mines can claim a credit of 20% of \nthe training program costs paid or incurred during the tax year \nfor training of qualified mine rescue team employees. The \nmaximum amount of training program costs that may be taken \ninto account annually for each qualified employee is $50,000. \nThe training costs include wages paid or incurred while the \nqualified employee is attending a training program.\nQualified employee. A qualified mine rescue team employee is \nany full-time employee of the taxpayer who is a miner eligible to \nserve for more than 6 months of the year as a mine rescue team \nmember. The employee must have completed, at a minimum, an \ninitial 20-hour course of instruction, as prescribed by the Mine \nSafety and Health Administration's Office of Educational Policy \nand Development, or received at least 40 hours of refresher \ntraining in such instruction. See 30 CFR section 49.8 for \nrefresher training requirements.\nWages. Wages qualifying for the credit generally have the same \nmeaning as wages subject to the Federal Unemployment Tax \nAct (FUTA), but without regard to any dollar limit.\nSpecific Instructions\nLine 2\nIn general, you must reduce your allowable training program \ncosts by the amount on line 2. This is required even if you \ncannot take the full credit this year and must carry part of it \nback or forward. If you capitalized any costs included on line 1, \nreduce the amount capitalized by the credit on line 2 \nattributable to these costs.\nLine 3\nEnter the total mine rescue team training credit from:\n• Schedule K-1 (Form 1065), Partner’s Share of Income, \nDeductions, Credits, etc., box 15 (code P); or\n• Schedule K-1 (1120-S), Shareholder’s Share of Income, \nDeductions, Credits, etc., box 13 (code P).\nPartnerships and S corporations must always report the \nabove credit on line 3. All other filers can report the above \ncredits directly on Form 3800, Part III, line 1u, and don’t need to \nfile this form.\nPaperwork Reduction Act Notice. We ask for the information \non this form to carry out the Internal Revenue laws of the United \nStates. You are required to give us the information. We need it \nto ensure that you are complying with these laws and to allow \nus to figure and collect the right amount of tax.\nYou are not required to provide the information requested on \na form that is subject to the Paperwork Reduction Act unless \nthe form displays a valid OMB control number. Books or \nrecords relating to a form or its instructions must be retained as \nlong as their contents may become material in the \nadministration of any Internal Revenue law. Generally, tax \nreturns and return information are confidential, as required by \nsection 6103.\nThe time needed to complete and file this form will vary \ndepending on individual circumstances. The estimated burden \nfor business taxpayers filing this form is approved under OMB \ncontrol number 1545-0123 and is included in the estimates \nshown in the instructions for their business income tax return.\nIf you have comments concerning the accuracy of these time \nestimates or suggestions for making this form simpler, we would \nbe happy to hear from you. See the instructions for the tax \nreturn with which this form is filed.\n" ]
f6198.pdf	1220 Form 6198 (PDF)	https://www.irs.gov/pub/irs-pdf/f6198.pdf	[ "Form 6198\n(Rev. December 2020)\nDepartment of the Treasury \nInternal Revenue Service\nAt-Risk Limitations\n▶ Attach to your tax return.\n▶ Go to www.irs.gov/Form6198 for instructions and the latest information.\nOMB No. 1545-0712\nAttachment \nSequence No. \n31\nName(s) shown on return\nIdentifying number\nDescription of activity (see instructions)\nPart I\nCurrent Year Profit (Loss) From the Activity, Including Prior Year Nondeductible Amounts. \nSee instructions.\n1\nOrdinary income (loss) from the activity (see instructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n1 \n2\nGain (loss) from the sale or other disposition of assets used in the activity (or of your interest in the\nactivity) that you are reporting on: \na\nSchedule D .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2a \nb\nForm 4797 \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2b\nc\nOther form or schedule \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2c \n3\nOther income and gains from the activity, from Schedule K-1 (Form 1065) or Schedule K-1 (Form\n1120-S), that were not included on lines 1 through 2c .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n3 \n4\nOther deductions and losses from the activity, including investment interest expense allowed from\nForm 4952, that were not included on lines 1 through 2c \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4 \n( ) \n5\nCurrent year profit (loss) from the activity. Combine lines 1 through 4. See the instructions before \ncompleting the rest of this form \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n5 \nPart II\nSimplified Computation of Amount at Risk. See the instructions before completing this part.\n6\nAdjusted basis (as defined in section 1011) in the activity (or in your interest in the activity) on the first \nday of the tax year. Do not enter less than zero .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n6 \n7\nIncreases for the tax year (see instructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n7 \n8\nAdd lines 6 and 7 .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n8 \n9\nDecreases for the tax year (see instructions) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n9 \n10a\nSubtract line 9 from line 8 \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\n10a\nb\nIf line 10a is more than zero, enter that amount here and go to line 20 (or complete Part III). \nOtherwise, enter -0- and see Pub. 925 for information on the recapture rules \n.\n.\n.\n.\n.\n.\n.\n.\n10b\nPart III\nDetailed Computation of Amount at Risk. If you completed Part III of Form 6198 for the prior year, see \nthe instructions.\n11\nInvestment in the activity (or in your interest in the activity) at the effective date. Do not enter less than \nzero \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n11 \n12\nIncreases at effective date .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n12 \n13\nAdd lines 11 and 12 \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n13 \n14\nDecreases at effective date .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n14 \n15\nAmount at risk (check box that applies):\na\nAt effective date. Subtract line 14 from line 13. Do not enter less than zero.\nb\nFrom your prior year Form 6198, line 19b. Do not enter the amount from line 10b of \nyour prior year form.\n}\n15 \n16\nIncreases since (check box that applies):\na\nEffective date\nb\nThe end of your prior year \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n16 \n17\nAdd lines 15 and 16 \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n17 \n18\nDecreases since (check box that applies):\na\nEffective date\nb\nThe end of your prior year \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n18 \n19a\nSubtract line 18 from line 17 \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\n19a\nb\nIf line 19a is more than zero, enter that amount here and go to line 20. Otherwise, enter -0- and see \nPub. 925 for information on the recapture rules \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n19b\nPart IV\nDeductible Loss\n20\nAmount at risk. Enter the larger of line 10b or line 19b \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n20 \n21\nDeductible loss. Enter the smaller of the line 5 loss (treated as a positive number) or line 20. See the\ninstructions to find out how to report any deductible loss and any carryover .\n.\n.\n.\n.\n.\n.\n.\n.\n21 ( ) \nNote: If the loss is from a passive activity, see the Instructions for Form 8582, Passive Activity Loss Limitations, or the \nInstructions for Form 8810, Corporate Passive Activity Loss and Credit Limitations, to find out if the loss is allowed under \nthe passive activity rules. If only part of the loss is subject to the passive activity loss rules, report only that part on Form \n8582 or Form 8810, whichever applies.\nFor Paperwork Reduction Act Notice, see the Instructions for Form 6198.\nCat. No. 50012Y\nForm 6198 (Rev. 12-2020)\n" ]
f943apr.pdf	1220 Form 943-A (PR) (PDF)	https://www.irs.gov/pub/irs-pdf/f943apr.pdf	[ "Formulario 943A-PR\n(Rev. diciembre de 2020)\nRegistro de la Obligación Contributiva \nFederal del Patrono Agrícola \nDepartment of the Treasury \nInternal Revenue Service \n▶ Visite www.irs.gov/Form943APR para obtener las instrucciones y la información más reciente. \n▶ Radíquelo con el Formulario 943-PR, 943-X (PR), 944(SP) o 944-X (SP).\nOMB No. 1545-0035 \nAño Natural \nNombre (como aparece en el Formulario 943-PR, 943-X (PR), 944(SP) o 944-X (SP))\nNúmero de identificación patronal (EIN)\nUsted tiene que completar este formulario si es depositante de itinerario bisemanal o si su obligación contributiva acumulada en un mes \ndeterminado fue $100,000 o más. Anote aquí su obligación contributiva, no los depósitos hechos. (El IRS obtiene toda la información \nrelacionada con los depósitos mediante el retiro electrónico de fondos). No cambie su obligación contributiva del año en curso por ajustes \ndeclarados en todo Formulario 943-X (PR) o 944-X (SP).\nenero —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \n31 \nA. Total de obligación \ncontributiva para el mes ▶\nfebrero —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \nB. Total de obligación \ncontributiva para el mes ▶\nmarzo —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \n31 \nC. Total de obligación \ncontributiva para el mes ▶\nabril —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \nD. Total de obligación \ncontributiva para el mes ▶\nmayo —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30\n31\nE. Total de obligación \ncontributiva para el mes ▶\njunio —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \nF. Total de obligación \ncontributiva para el mes ▶\nPara el Aviso sobre la Ley de Confidencialidad de Información y la Ley de \nReducción de Trámites, vea las instrucciones por separado.\nCat. No. 17031N \n Form 943A-PR (Rev. 12-2020) \n", "Formulario 943A-PR (Rev. 12-2020) \nPágina 2 \njulio —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \n31 \nG. Total de obligación \ncontributiva para el mes ▶\nagosto —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30\n31\nH. Total de obligación \ncontributiva para el mes ▶\nseptiembre —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \nI. Total de obligación \ncontributiva para el mes ▶\noctubre —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \n31\nJ. Total de obligación \ncontributiva para el mes ▶\nnoviembre —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30\nK. Total de obligación \ncontributiva para el mes ▶\ndiciembre —Obligación Contributiva \n1 \n2 \n3 \n4 \n5 \n6 \n7 \n8 \n9 \n10 \n11 \n12 \n13 \n14 \n15 \n16 \n17 \n18 \n19 \n20 \n21 \n22 \n23 \n24 \n25 \n26 \n27 \n28 \n29 \n30 \n31\nL. Total de obligación \ncontributiva para el mes ▶\nM. Total de obligación contributiva para el año (sume las líneas A a L). El total tiene que ser \nigual a la cantidad de la línea 13 del Formulario 943-PR .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\n Form 943A-PR (Rev. 12-2020) \n" ]
f5471sj.pdf	1220 Form 5471 (Schedule J) (PDF)	https://www.irs.gov/pub/irs-pdf/f5471sj.pdf	[ "SCHEDULE J \n(Form 5471)\n(Rev. December 2020)\nDepartment of the Treasury \nInternal Revenue Service\nAccumulated Earnings & Profits (E&P) of Controlled Foreign Corporation\n▶ Attach to Form 5471. \n▶ Go to www.irs.gov/Form5471 for instructions and the latest information.\nOMB No. 1545-0123\nName of person filing Form 5471\nIdentifying number\nName of foreign corporation\nEIN (if any)\nReference ID number (see instructions)\na\nSeparate Category (Enter code—see instructions.) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nb\nIf code 901j is entered on line a, enter the country code for the sanctioned country (see instructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nPart I\nAccumulated E&P of Controlled Foreign Corporation\nCheck the box if person filing return does not have all U.S. shareholders’ information to complete an amount in column (e) (see instructions).\nImportant: Enter amounts in functional currency. \n(a) \nPost-2017 E&P Not \nPreviously Taxed \n(post-2017 section \n959(c)(3) balance)\n(b) \nPost-1986 \nUndistributed Earnings \n(post-1986 and pre-2018 \nsection 959(c)(3) balance)\n(c) \nPre-1987 E&P Not \nPreviously Taxed \n(pre-1987 section \n959(c)(3) balance)\n(d) \nHovering Deficit and \nDeduction for \nSuspended Taxes\n(e) Previously Taxed E&P (see instructions)\n \n \n \n \n(i) Reclassified section \n965(a) PTEP\n(ii) Reclassified section \n965(b) PTEP\n1a \n \nBalance at beginning of year (as reported on prior \nyear Schedule J) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\nb Beginning balance adjustments (attach statement) \nc Adjusted beginning balance (combine lines 1a and 1b)\n2a Reduction for taxes unsuspended under anti-splitter rules\nb \n \nDisallowed deduction for taxes suspended under \nanti-splitter rules .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n3 \nCurrent year E&P (or deficit in E&P) (enter amount\nfrom applicable line 5c of Schedule H) .\n.\n.\n.\n4 \n \nE&P attributable to distributions of previously taxed \nE&P from lower-tier foreign corporation .\n.\n.\n5a E&P carried over in nonrecognition transaction .\nb \n \nReclassify deficit in E&P as hovering deficit after \nnonrecognition transaction \n.\n.\n.\n.\n.\n.\n.\n6\nOther adjustments (attach statement) .\n.\n.\n.\n7 \n \nTotal current and accumulated E&P (combine lines \n1c through 6) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n8 \n \nAmounts reclassified to section 959(c)(2) E&P from \nsection 959(c)(3) E&P .\n.\n.\n.\n.\n.\n.\n.\n.\n9\nActual distributions .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n10 \n \nAmounts reclassified to section 959(c)(1) E&P from \nsection 959(c)(2) E&P .\n.\n.\n.\n.\n.\n.\n.\n.\n11 \n \nAmounts included as earnings invested in U.S. property \nand reclassified to section 959(c)(1) E&P (see instructions)\n12\nOther adjustments (attach statement) .\n.\n.\n.\n13 \n \nHovering deficit offset of undistributed post-\ntransaction E&P (see instructions) .\n.\n.\n.\n.\n14 \nBalance at beginning of next year (combine lines 7 through 13) \nFor Paperwork Reduction Act Notice, see the Instructions for Form 5471.\nCat. No. 21111K\nSchedule J (Form 5471) (Rev. 12-2020)\n", "Schedule J (Form 5471) (Rev. 12-2020)\nPage 2\nPart I\nAccumulated E&P of Controlled Foreign Corporation (continued)\n(e) Previously Taxed E&P (see instructions)\n(iii) General section \n959(c)(1) PTEP\n(iv) Reclassified section 951A PTEP\n(v) Reclassified section 245A(d) PTEP\n(vi) Section 965(a) PTEP\n(vii) Section 965(b) PTEP\n1a\nb\nc\n2a\nb\n3\n4 \n5a\nb\n6\n7 \n8 \n9\n10 \n11 \n12\n13\n14 \n(e) Previously Taxed E&P (see instructions)\n(f) \nTotal Section 964(a) E&P \n(combine columns (a), (b), (c), \nand (e)(i) through (e)(x))\n(viii) Section 951A PTEP\n(ix) Section 245A(d) PTEP\n(x) Section 951(a)(1)(A) PTEP\n \n1a\nb\nc\n2a\nb\n3\n4 \n5a\nb\n6\n7 \n8 \n9\n10 \n11 \n12\n13\n14 \nSchedule J (Form 5471) (Rev. 12-2020)\n", "Schedule J (Form 5471) (Rev. 12-2020)\nPage 3\nPart II\nNonpreviously Taxed E&P Subject to Recapture as Subpart F Income (section 952(c)(2))\nImportant: Enter amounts in functional currency.\n1\nBalance at beginning of year \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\n1\n2\nAdditions (amounts subject to future recapture) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\n2\n3\nSubtractions (amounts recaptured in current year) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\n3\n4\nBalance at end of year (combine lines 1 through 3) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\n4\nSchedule J (Form 5471) (Rev. 12-2020)\n" ]
f965a.pdf	0121 Form 965-A (PDF)	https://www.irs.gov/pub/irs-pdf/f965a.pdf	[ "Form 965-A\n(Rev. January 2021)\nIndividual Report of Net 965 Tax Liability\nDepartment of the Treasury \nInternal Revenue Service\n▶ Go to www.irs.gov/Form965A for instructions and the latest information.\nOMB No. 1545-0074\nAttachment \nSequence No. 76A\nCheck this box if this is an amended report \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n▶\nName of taxpayer with a net 965 tax liability\nIdentifying number\nTaxable year of reporting\nPart I\nReport of Net 965 Tax Liability and Election To Pay in Installments \n(a) \nYear of Section 965(a) \nInclusion, Liability Assumed, \nor Liability Triggering Event \n(see instructions)\n(b) \nTaxpayer’s Net Tax Liability \nwith all \n965 amounts \n(see instructions)\n(c) \nTaxpayer’s Net Tax Liability \nwithout \n965 amounts \n(see instructions)\n(d) \nNet 965 Tax Liability \n(subtract column (c) from column (b))\n(e) \nS Corporation Shareholder Total \nDeferred Net 965 Tax Liability \n(line total from Part III, column (g), \nsee instructions)\n1\n2017\n1\n2\n2018\n2\n3\n2019\n3\n4\n2020\n4\n5\n5\n6\n6\n7\n7\n8\n8\n(f) \nNet 965 Tax Liability \neligible for installment payment election \n(subtract column (e) from column (d), \nsee instructions)\n(g) \nInstallment \nElection \nMade\n(h) \nNet 965 Tax Liability \nto be paid in full for Year 1 \n(if column (g) is “No,” enter amount \nfrom column (f))\n(i) \nNet 965 Tax Liability \nto be paid in installments \n(if column (g) is “Yes,” enter amount \nfrom column (f) and see instructions) \n(j) \nNet 965 Tax Liability \nTransferred (Out), Transferred In, \nor Subsequent Adjustments, if any \n(see instructions)\n(k) \nTax Identification Number \nof buyer/transferee or \nseller/transferor\n \n \nYes\nNo\n \n \n \n \n \n1\n1\n2\n2\n3\n3\n4\n4\n5\n5\n6\n6\n7\n7\n8\n8\nPart II\nRecord of Amount of Net 965 Tax Liability Paid by the Taxpayer (see instructions) \n(a) \nYear of Section 965(a) \nInclusion, Liability Assumed, \nor Triggering Event\n(b) \nPaid for Year 1\n(c) \nPaid for Year 2\n(d) \nPaid for Year 3\n(e) \nPaid for Year 4\n(f) \nPaid for Year 5\n1\n2017\n1\n2\n2018\n2\n3\n2019\n3\n4\n2020\n4\n5\n5\n6\n6\n7\n7\n8\n8\nFor Privacy Act and Paperwork Reduction Act Notice, see the separate instructions.\nCat. No. 71277H\nForm 965-A (Rev. 1-2021)\n", "Form 965-A (Rev. 1-2021)\nPage 2\nPart II\nRecord of Amount of Net 965 Tax Liability Paid by the Taxpayer (continued) \n(g) \nPaid for Year 6\n(h) \nPaid for Year 7\n(i) \nPaid for Year 8\n(j) \nNet 965 Tax Liability Remaining Unpaid \n(see instructions)\n(k) \nNet 965 Tax Liability \nPaid for the Reporting Year\n1\n1\n2\n2\n3\n3\n4\n4\n5\n5\n6\n6\n7\n7\n8\n8\nTotals .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nPart III\nS Corporation Shareholder: Report of Calculation of Net 965 Tax Liability Related to 965 Amounts Allocated From an S Corporation and \nElection To Defer Such Net 965 Tax Liability\nYear \nof \n965(a) \nInclusion\n(a) \nS Corporation Name\n(b) \nS Corporation \nTax Identification \nNumber\n(c) \nTaxpayer’s Net Tax Liability \nwith only 965 amounts \nfrom this S Corporation \n(see instructions)\n(d) \nTaxpayer’s Net Tax Liability \nwithout 965 amounts \n(see instructions)\n(e) \nNet 965 Tax Liability \nrelated to 965 amounts from \nthis S Corporation (subtract \ncolumn (d) from column (c))\n(f) \nDeferral \nElection \nMade\n(g) \nDeferred Net 965 Tax Liability\n(if column (f) is “Yes,” enter \namount from column (e))\n1\n \n \n \n \n \n \nYes\nNo\n \n \n2017\n \n \nTotal \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\n2\n \n \n \n \n \n \n \n \n \n \n2018\n \n \nTotal \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\n3\n \n \n \n \n \n \n \n \n \n \n2019\n \n \nTotal \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\n4\n \n \n \n \n \n \n \n \n \n \n2020\n \n \nTotal \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nForm 965-A (Rev. 1-2021)\n", "Form 965-A (Rev. 1-2021)\nPage 3\nPart IV\nAnnual Report of Deferred Net 965 Tax Liability Related to 965 Amounts Allocated From S Corporations \n(required every year until the liability is fully paid)\n(a) \nElection or \nTransfer Year\n(b) \nS Corporation Name\n(c) \nS Corporation \nTax Identification Number\n(d) \nBeginning Deferred \nNet 965 Tax Liability \n(see instructions)\n1\n1\n2\n2\n3\n3\n4\n4\n5\n5\n6\n6\n7\n7\n8\n8\n9\n9\n10\n10\n( )\n( )\n( )\n( )\n( )\n( )\n( )\n( )\n( )\n( )\n(e) \nReserved for Future Use\n(f) \nNet 965 Tax Liability \nTriggered \n(see instructions)\n(g) \nDeferred 965 Net Tax Liability \nTransferred (Out) or \nTransferred In by Agreement, if any \n(see instructions)\n(h) \nTax Identification Number \nof Transferee or Transferor\n(i) \nDeferred Net Tax Liability \nat the end of this Reporting Year \n(add columns (d), (f), and (g)) \n(see instructions)\n1\n1\n2\n2\n3\n3\n4\n4\n5\n5\n6\n6\n7\n7\n8\n8\n9\n9\n10\n10\nTotal .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nIf more lines are needed for any Part on this form, attach additional sheets.\nForm 965-A (Rev. 1-2021)\n" ]
f965b.pdf	0121 Form 965-B (PDF)	https://www.irs.gov/pub/irs-pdf/f965b.pdf	[ "Form 965-B\n(Rev. January 2021)\nCorporate and Real Estate Investment Trust (REIT) Report of Net 965 \nTax Liability and Electing REIT Report of 965 Amounts\nDepartment of the Treasury \nInternal Revenue Service\n▶ Go to www.irs.gov/Form965B for instructions and the latest information.\nOMB No. 1545-0123\nCheck this box if this is an amended report \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n▶\nName of taxpayer or REIT\nIdentifying number\nTaxable year of reporting\nREITs Electing To Account for Section 965 Amounts Over Time Must Fill Out Part III.\nPart I\nReport of Net 965 Tax Liability and Election To Pay in Installments \n(a) \nYear of \nSection \n965(a) \nInclusion or \nLiability \nAssumed \n(see instructions)\n(b) \nTaxpayer’s Net Tax Liability \nWith all \n965 Amounts \n(see instructions)\n(c) \nTaxpayer’s Net Tax Liability \nWithout \n965 Amounts \n(see instructions)\n(d) \nNet 965 Tax Liability \n(subtract column (c) \nfrom column (b))\n(e) \nInstallment \nElection \nMade\n(f) \nNet 965 Tax Liability \nTo Be Paid in Full in Year 1 \n(if column (e) is “No,” enter \namount from column (d))\n(g) \nNet 965 Tax Liability \nTo Be Paid in Installments \n(if column (e) is “Yes,” enter \namount from column (d) \nand see instructions) \n(h) \nNet 965 Tax Liability \nTransferred (Out), \nTransferred In, or \nSubsequent Adjustments, \nif any (see instructions)\n(i) \nTax \nIdentification \nNumber \nof Buyer/\nTransferee or \nSeller/ \nTransferor\n \n \n \n \nYes\nNo\n \n \n \n \n1\n2017\n2\n2018\n3\n2019\n4\n2020\n5\n6\n7\n8\nPart II\nRecord of Amount of Net 965 Tax Liability Paid by the Taxpayer (see instructions) \n(a) \nYear of Section 965(a) \nInclusion or \nLiability Assumed \n(see instructions)\n(b) \nPaid for Year 1\n(c) \nPaid for Year 2\n(d) \nPaid for Year 3\n(e) \nPaid for Year 4\n(f) \nPaid for Year 5\n1\n2017\n2\n2018\n3\n2019\n4\n2020\n5\n6\n7\n8\n(g) \nPaid for Year 6\n(h) \nPaid for Year 7\n(i) \nPaid for Year 8\n(j) \nNet 965 Tax Liability \nRemaining Unpaid (see instructions)\n(k) \nNet 965 Tax Liability \nPaid for the Reporting Year\n1\n2\n3\n4\n5\n6\n7\n8\nTotals .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\nFor Privacy Act and Paperwork Reduction Act Notice, see the separate instructions.\nCat. No. 71278S\nForm 965-B (Rev. 1-2021)\n", "Form 965-B (Rev. 1-2021)\nPage 2\nPart III\nElecting REIT Report of Section 965 Amounts Accounted for Over Time (see instructions)\n(a) \nTax Year of \nSection 965(a) Inclusion and \nSection 965(c) Deduction\n(b) \nAmount Elected To Be \nAccounted for Over Time\n(c) \nPortion Accounted for in \nYear 1\n(d) \nPortion Accounted for in \nYear 2\n(e) \nPortion Accounted for in \nYear 3\n(f) \nPortion Accounted for in \nYear 4\n1a\n2017 Section 965(a) Inclusion\n1b\n2017 Section 965(c) Deduction\n2a\n2018 Section 965(a) Inclusion\n2b\n2018 Section 965(c) Deduction\n3a\n2019 Section 965(a) Inclusion\n3b\n2019 Section 965(c) Deduction\n4a\n2020 Section 965(a) Inclusion\n4b\n2020 Section 965(c) Deduction\n(g) \nPortion Accounted for in \nYear 5\n(h) \nPortion Accounted for in \nYear 6\n(i) \nPortion Accounted for in \nYear 7\n(j) \nPortion Accounted for in \nYear 8\n(k) \nAmount Remaining To Be \nAccounted for\n(l) \nPortion Accounted for \nin This Reporting Year\n1a\n1b\n2a\n2b\n3a\n3b\n4a\n4b\nTotals .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n. ▶\nIf more lines are needed for any Parts on this form, attach additional sheets.\nForm 965-B (Rev. 1-2021)\n" ]
f2438.pdf	1220 Form 2438 (PDF)	https://www.irs.gov/pub/irs-pdf/f2438.pdf	[ "Form 2438\n(Rev. December 2020)\nDepartment of the Treasury \nInternal Revenue Service \nUndistributed Capital Gains Tax Return \n▶ Attach a copy of this form to Form 1120-RIC or to Form 1120-REIT. \n▶ Go to www.irs.gov/Form2438 for instructions and the latest information.\nOMB No. 1545-0123\nFor calendar year 20\n or tax year beginning\n, 20\n , ending\n, 20\nPlease \nType \nor \nPrint \nName of fund or REIT\nEmployer identification number\nNumber, street, and room or suite no. (If a P.O. box, see instructions.)\nCity or town, state, and ZIP code\nPart I \nShort-Term Capital Gains and Losses—Assets Held One Year or Less \n(a) Description of property \n(Example, 100 shares of Z Co.) \n(b) Date acquired \n(mo., day, yr.) \n(c) Date sold \n(mo., day, yr.) \n(d) Sales price \n(see instructions) \n(e) Cost or \nother basis \n(see instructions) \n(f) Gain or (loss) \n ((d) less (e)) \n1 \n2 \nShort-term capital gain from installment sales from Form 6252, line 26 or 37 .\n.\n.\n.\n.\n.\n.\n.\n2 \n3 \nUnused capital loss carryover (attach computation) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n3 ( )\n4 \nNet short-term capital gain or (loss). Combine lines 1 through 3. See instructions .\n.\n.\n.\n.\n.\n4 \nPart II \nLong-Term Capital Gains and Losses—Assets Held More Than One Year \n \n \n \n \n \n \n5 \n6 \nGain from Form 4797, column (g), line 7 or 9 \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n \n6 \n7 \nLong-term capital gain from installment sales from Form 6252, line 26 or 37 .\n.\n.\n.\n.\n.\n.\n.\n7 \n8 \nNet long-term capital gain. Combine lines 5 through 7 .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n8 \nPart III \nSummary of Parts I and II \n9 \na Net capital gain. Enter excess of net long-term capital gain (line 8) over net short-term capital loss \n(line 4) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n9a \nb Capital gain dividends \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n9b \n10 \nUndistributed capital gains. Subtract line 9b from line 9a .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n10 \n11 \nAmount of undistributed capital gains on line 10 designated under section 852(b)(3)(D) or \n857(b)(3)(C) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n \n11 \n12 \nAmount of undistributed capital gains not designated under section 852(b)\n(3)(D) or 857(b)(3)(C). Subtract line 11 from line 10. See instructions .\n.\n. \n12 \n13\nCapital gains tax. Multiply line 11 by 21% (0.21) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n \n13\nSign \nHere\nUnder penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, \ncorrect, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.\n▲\nSignature of officer\nDate\n▲\nTitle\nPaid \nPreparer \nUse Only\nPrint/Type preparer’s name\nPreparer’s signature\nDate\nCheck if \nself-employed\nPTIN\nFirm’s name ▶\nFirm’s address ▶\nFirm’s EIN ▶\nPhone no.\nFor Paperwork Reduction Act Notice, see instructions. \nCat. No. 11856I \nForm 2438 (Rev. 12-2020) \n", "Form 2438 (Rev. 12-2020)\nPage 2 \nGeneral Instructions \nSection references are to the \nInternal Revenue Code. \nFuture Developments\nFor the latest information about \ndevelopments related to Form 2438 \nand its instructions, such as legislation \nenacted after they were published, go \nto www.irs.gov/Form2438.\nWho Must File \nRegulated investment companies \n(RICs) and real estate investment \ntrusts (REITs) file Form 2438 if the \nRIC or REIT is electing to designate \nundistributed capital gains under \nsection 852(b)(3)(D) or 857(b)(3)(C). \nIf a RIC has more than one fund, \neach fund must file a separate Form \n2438. The term “fund” as used in \nthese instructions refers to the \ndefinition in section 851(g) and to \nany RIC that does not have more \nthan one portfolio of assets. \nPurpose of Form \nForm 2438 is used by RICs or REITs \nto figure income tax on undistributed \ncapital gains designated under \nsection 852(b)(3)(D) or section \n857(b)(3)(C). \nSee the instructions for Schedule \nD (Form 1120) and Form 8949 for a \ndefinition of capital assets and \ninformation on figuring and reporting \ncapital gains and losses.\nWhen To File \nFile Form 2438 by the 30th day after \nthe end of the RIC’s or the REIT’s \ntax year. \nWhere To File \nFile the original form with the: \nDepartment of the Treasury \nInternal Revenue Service Center \nKansas City, MO 64999\nIn addition, attach a copy of Form \n2438 to Form 1120-RIC or Form \n1120-REIT. \nWho Must Sign \nForm 2438 must be signed and \ndated by: \n• The president, vice president, \ntreasurer, assistant treasurer, chief \naccounting officer; or \n• Any other corporate officer (such \nas tax officer) authorized to sign. \nIf a return is filed on behalf of a RIC \nor REIT by a receiver, trustee, or \nassignee, the fiduciary must sign the \nreturn, instead of the corporate \nofficer. Returns and forms signed by a \nreceiver or trustee in bankruptcy on \nbehalf of a RIC or REIT must be \naccompanied by a copy of the order \nor instructions of the court authorizing \nsigning of the return or form.\nFor a return that is being filed for a \nseries fund (discussed in section \n851(g)), the return may be signed by \nany officer authorized to sign for the \nRIC in which the fund is a series.\nIf a corporate officer completes \nForm 2438, the paid preparer space \nshould remain blank. Anyone who \nprepares Form 2438 but doesn’t \ncharge the RIC or REIT shouldn’t \nsign the return. Generally, anyone \nwho is paid to prepare Form 2438 \nmust sign it and fill in the Paid \nPreparer Use Only area. \nPaid preparer. The paid preparer \nmust complete the Paid Preparer \nUse Only area (including signing the \nform in the space provided for the \npreparer’s signature) and give a \ncopy of Form 2438 to the taxpayer.\nPenalty for Late Filing of \nReturn \nA RIC or REIT that doesn’t file its tax \nreturn by the due date, including \nextensions, may be penalized 5% of \nthe unpaid tax for each month or \npart of the month the return is late, \nup to a maximum of 25% of the \nunpaid tax. The minimum penalty for \na return that is more than 60 days \nlate is the smaller of the tax due or \n$435. The penalty won’t be imposed \nif the RIC or REIT can show that the \nfailure to file on time was due to \nreasonable cause.\nNote: The minimum penalty amount \nmay be adjusted for inflation. See \nthe instructions for your applicable \nincome tax return for the minimum \npenalty amount for the current tax \nyear. \nPenalty for Late Payment of \nTax \nA RIC or REIT that doesn’t pay the \ntax when due may generally be \npenalized 1/2 of 1% of the unpaid tax \nfor each month or part of a month \nthe tax is not paid, up to a maximum \nof 25% of the unpaid tax. The \npenalty won’t be imposed if the RIC \nor REIT can show that the failure to \npay on time was due to reasonable \ncause.\nReasonable cause determinations. \nIf the RIC or REIT receives a notice \nabout penalties after it files its return, \nsend the IRS an explanation and we \nwill determine if the RIC or REIT \nmeets the reasonable cause criteria. \nDo not attach an explanation when \nthe RIC’s or REIT’s return is filed.\nElectronic Deposit \nRequirement\nRICs and REITs must use electronic \nfunds transfers to make all federal \ntax deposits (such as deposits of \nemployment tax, excise tax, and \ncorporate income tax). Generally, \nelectronic fund transfers are made \nusing the Electronic Federal Tax \nPayment System (EFTPS). However, \nif you don’t want to use EFTPS, you \ncan arrange for your tax \nprofessional, financial institution, \npayroll service, or other trusted third \nparty to make deposits on your \nbehalf. Also, you may arrange for \nyour financial institution to submit a \nsame-day tax wire payment \n(discussed below) on your behalf. \nEFTPS is a free service provided by \nthe Department of the Treasury. \nServices provided by your tax \nprofessional, financial institution, \npayroll service, or other third party \nmay have a fee. \nFor more information about \nEFTPS, or to enroll in EFTPS, visit \nthe EFTPS website at \nwww.eftps.gov or call \n1-800-555-4477 (TTY/TDD \n1-800-733-4829). \nDepositing on time. For any deposit \nmade by EFTPS to be on time, the \nRIC or REIT must submit the deposit \nby 8 p.m. Eastern time on the day \nbefore the date the deposit is due. If \nthe RIC or REIT uses a third party to \nmake the deposits on its behalf, they \nmay have different cutoff times.\n", "Form 2438 (Rev. 12-2020)\nPage 3 \nSame-day wire payment option. If \nthe RIC or REIT fails to submit a \ndeposit transaction on EFTPS by \n8 p.m. Eastern time the day before \nthe date a deposit is due, it can still \nmake the deposit on time by using \nthe Federal Tax Collection Service \n(FTCS). To use the same-day wire \npayment method, the RIC or REIT \nwill need to make arrangements with \nits financial institution ahead of time \nregarding availability, deadlines, and \ncosts. Financial institutions may \ncharge a fee for payments made this \nway. To learn more about the \ninformation the RIC or REIT will need \nto provide to its financial institution \nto make a same-day wire payment, \nvisit the IRS website at www.irs.gov/\nSameDayWire.\nSpecific Instructions \nPeriod covered. Fill in the tax year \nspace at the top of the form. \nAddress. Include the suite, room, or \nother unit number after the street \naddress. If the Post Office does not \ndeliver mail to the street address \nand the RIC or REIT has a P.O. box, \nshow the box number instead of the \nstreet address. \nColumn (b)—Date acquired. A \nRIC’s or REIT’s acquisition date for \nan asset it held on January 1, 2001, \nfor which it made an election to \nrecognize any gain (under section \n311 of the Taxpayer Relief Act of \n1997) is the date of the deemed sale \nand reacquisition. \nColumn (d). Enter either gross sales \nprice or net sales price. If net sales \nprice is entered, do not increase the \ncost or other basis in column (e) by \nany expenses reflected in the net \nsales price. \nLines 1 and 5 \nColumn (e). If gross sales price is \nreported in column (d), increase the \ncost or other basis by any expense \nof sale such as broker’s fees, \ncommissions, or option premiums \nbefore entering an amount in \ncolumn (e). \nA RIC’s or REIT’s basis in an asset \nit held on January 1, 2001, for which \nthe RIC or REIT made an election to \nrecognize any gain (under section \n311 of the Taxpayer Relief Act of \n1997) is the asset’s closing market \nprice or fair market value, whichever \napplies, on the date of the deemed \nsale and reacquisition, whether the \ndeemed sale resulted in a gain or \nunallowed loss. \nLine 4 \nEnter any net short-term capital gain \nfrom line 4 in Part I of Form 8949. \nAlso identify the gain as “Net short-\nterm capital gain from line 4, Form \n2438” in column (a) of Form 8949. \nSee Form 8949, Schedule D (Form \n1120), and the related instructions \nfor details.\nLine 12\nEnter the amount from line 12 in \nPart II of Form 8949. Also identify \nthe gain as “Undistributed capital \ngains not designated (from Form \n2438)” in column (a) of Form 8949. \nSee Form 8949, Schedule D (Form \n1120), and the related instructions \nfor details. \nLine 13\nDeposit the tax due by the 30th day \nafter the end of the tax year.\nPaperwork Reduction Act Notice. \nWe ask for the information on this \nform to carry out the Internal \nRevenue laws of the United States. \nYou are required to give us the \ninformation. We need it to ensure \nthat you are complying with these \nlaws and to allow us to figure and \ncollect the right amount of tax. \nYou are not required to provide \nthe information requested on a form \nthat is subject to the Paperwork \nReduction Act unless the form \ndisplays a valid OMB control \nnumber. Books or records relating to \na form or its instructions must be \nretained as long as their contents \nmay become material in the \nadministration of any Internal \nRevenue law. Generally, tax returns \nand return information are \nconfidential, as required by section \n6103. \nThe time needed to complete and \nfile this form will vary depending on \nindividual circumstances. The \nestimated burden for business \ntaxpayers filing this form is approved \nunder OMB control number \n1545-0123 and is included in the \nestimates shown in the instructions \nfor their business income tax return.\nIf you have comments concerning \nthe accuracy of these time estimates \nor suggestions for making this form \nsimpler, we would be happy to hear \nfrom you. You can send us \ncomments from www.irs.gov/\nFormComments. Or you can write to \nthe Internal Revenue Service, Tax \nForms and Publications Division, \n1111 Constitution Ave. NW, IR-6526, \nWashington, DC 20224.\nDo not send the tax form to this \noffice. Instead, see Where To File, \nearlier.\n" ]
p5467.pdf	1120 Publ 5467 (PDF)	https://www.irs.gov/pub/irs-pdf/p5467.pdf	[ "Publication 5467 (11-2020) Catalog Number 75110T Department of the Treasury Internal Revenue Service www.irs.gov\nReporting \nUnemployment \nCompensation \non a Tax \nReturn\nIn January, people who received unemployment \nbenefits in the prior year will get a Form \n1099-G, Certain Government Payments from \nthe agency paying the benefits. The agency \nwill either automatically send a hard copy or, if \nthe agency does not mail the form, recipients \nwill need to visit the agency’s website to get an \nelectronic version of Form 1099-G.\nThe Form 1099-G will show the amount of \nunemployment compensation received in Box \n1 and any federal income tax withheld in Box \n4. Taxpayers must report the unemployment \ncompensation income and withholding on the \nappropriate lines on their federal tax return. \n1099-G\nSome states do not mail Form 1099-G, recipients need \nto get the electronic version from their state’s website\nMore information on unemployment is available \nin the Unemployment Benefits chapter in \nPublication 525, Taxable and Nontaxable \nIncome on IRS.gov.\nwww.irs.gov \n" ]
p5467sp.pdf	1120 Publ 5467 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5467sp.pdf	[ " \nPublication 5467 (sp) (11-2020) Catalog Number 75111E Department of the Treasury Internal Revenue Service www.irs.gov\nCómo reportar \ncompensación \nde desempleo \nen la declaración \nde impuestos\nEn enero, aquellas personas que recibieron \nbeneficios de desempleo el año anterior recibirán \nun Formulario 1099-G, Ciertos Pagos del \nGobierno de parte de la agencia que haya \npagado esos beneficios. Esa agencia le enviará \nlos documentos ya sea automáticamente por \ncorreo postal o bien, si la agencia no envía \ndocumentos de papel por correo, los beneficiarios \ntendrán que visitar el sitio web de la agencia para \nobtener la versión electrónica del Formulario \n1099-G.\nEl Formulario 1099-G mostrará la cantidad total \nque recibió de compensación por desempleo en \nla casilla 1 y cualquier impuesto federal retenido \nen la casilla 4. Los contribuyentes deben reportar \nel ingreso por compensación de desempleo y \nlas retenciones en las líneas adecuadas en la \ndeclaración de impuestos federal. \n1099-G\nAlgunos estados no envían por correo el formulario \n1099-G, y los beneficiarios necesitan obtener la versión \nelectrónica en el sitio web de su estado\nMás información sobre los beneficios de \ndesempleo están disponibles en el capítulo de \nBeneficios de desempleo de la Publicación 525, \nIngreso Tributable y no Tributable en IRS.gov \nwww.irs.gov \n" ]
p5461asp.pdf	1120 Publ 5461-A (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5461asp.pdf	[ "Publication 5461-A (sp) (11-2020) Catalog Number 75090M Department of the Treasury Internal Revenue Service www.irs.gov\nUse autenticación de múltiples factores\nRecuerde usar las opciones de autenticación de múltiples factores que ofrecen \nlos proveedores de software de impuestos:\n Todos los proveedores de software de impuestos ofrecen opciones de \nautenticación de múltiples factores en sus productos para contribuyentes y \nprofesionales de impuestos. Verifique las características de seguridad de su \ncuenta para activar esta función.\n Una autenticación de múltiples factores protege las cuentas en línea al \nrequerir un segundo factor de verificación de identidad, además de su \nnombre de usuario y contraseña. Por ejemplo, esta segunda característica \npuede ser un código enviado a su teléfono móvil. \n Una autenticación de múltiples factores ofrece una capa crítica de protección \npara sus cuentas en línea. \nwww.irs.gov/cumbredeseguridad\n" ]
p5461a.pdf	1120 Publ 5461-A (PDF)	https://www.irs.gov/pub/irs-pdf/p5461a.pdf	[ " \n \n \n \nwww.irs.gov/securitysummit \nUse Multi-Factor Authentication \nRemember to use multi-factor authentication options being offered \nby tax software providers: \n All tax software providers are offering multi-factor authentication options on \nproducts for both taxpayers and tax professionals. Check your account’s \nsecurity features to activate this feature. \n Multi-factor authentication protects online accounts by requiring a second \nidentity verification factor in addition to your username and password. For \nexample, this second feature may be a code sent to your mobile phone. \n Multi-factor authentication provides a critical layer of protection for your \nonline accounts. \nPublication 5461-A (11-2020) Catalog Number 75058M Department of the Treasury Internal Revenue Service www.irs.gov \n" ]
f965sf.pdf	1220 Form 965 (Schedule F) (PDF)	https://www.irs.gov/pub/irs-pdf/f965sf.pdf	[ "SCHEDULE F \n(Form 965)\n(Rev. December 2020)\nForeign Taxes Deemed Paid by Domestic Corporation\nDepartment of the Treasury \nInternal Revenue Service\nFor foreign corporations with respect to which the filer has a section 965(a) inclusion during its 2020 tax year\n▶ Attach to Form 965. \n▶ Go to www.irs.gov/Form965 for instructions and the latest information. \nOMB No. 1545-0123\nName of person filing this return\nIdentifying number\na Separate Category (Enter code—see instructions.) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nb\nIf code 901j is entered on line a, enter the country code for the sanctioned country (see instructions) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nName of Deferred Foreign Income Corporation \n(DFIC)\n(a) \nEIN or Reference ID \nNumber of the \nForeign Corporation \n(see instructions)\n(b) \nEIN or Reference ID \nNumber of K-1 Issuer \n(if any) \n(see instructions)\n(c) \nU.S. Tax Year End \n(Year/Month) of DFIC\n(d) \nCountry of Incorporation \n(use country codes) \n(see instructions)\n(e)(1) \nSection 965(a) Inclusion \nin U.S. Dollars\n(e)(2) \nSection 965(a) Inclusion \nin Functional Currency\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15 \n16 \n \nTotal from pass-throughs (sum of \nlines 1–15) (see instructions) .\n.\n.\nFor Privacy Act and Paperwork Reduction Act Notice, see the separate instructions.\nSchedule F (Form 965) (Rev. 12-2020)\nCat. No. 71326R\n", "Schedule F (Form 965) (Rev. 12-2020)\nPage 2\n(f) \nPost-1986 \nUndistributed Earnings \nin Functional Currency\n(g) \nDivide Column (e)(2) \nby Column (f) \n(capped at 100%)\n(h) \nOpening Balance \nin Post-1986 \nForeign Income Taxes\n(i) \nForeign Taxes Paid \nfor Tax Year Indicated\n(j) \nForeign Taxes Deemed Paid \nfor Tax Year Indicated\n(k) \nPost-1986 \nForeign Income Taxes \n(add columns (h), (i), and (j))\n(l) \nTaxes Deemed Paid \n(multiply column (g) \nby column (k))\n1\n2\n3\n4\n5\n6\n7\n8\n9\n10\n11\n12\n13\n14\n15 \n16\nAdd schedules as needed. \nSchedule F (Form 965) (Rev. 12-2020)\n" ]
f965sh.pdf	1220 Form 965 (Schedule H) (PDF)	https://www.irs.gov/pub/irs-pdf/f965sh.pdf	[ "SCHEDULE H \n(Form 965)\n(Rev. December 2020)\nAmounts Reported on Forms 1116 and 1118 \nand Disallowed Foreign Taxes\nDepartment of the Treasury \nInternal Revenue Service\n▶ Attach to Form 965.\n▶ Go to www.irs.gov/Form965 for instructions and the latest information.\nOMB No. 1545-0123\nName of person filing this return\nIdentifying number\nSECTION 1—Amounts Reported on Forms 1116 and 1118 and Disallowed Foreign Taxes\na\nSeparate Category (Enter code–see instructions.) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\nb\nIf code 901j is entered on line a, enter the country code for the sanctioned country (see instructions) .\n.\n ▶\n2020 Tax Year \n1\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n1\n2\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2\n3 \n \nSection 965(a) inclusion in U.S. dollars with respect to pass-throughs from Schedule F, \ncolumn (e)(1), line 16. Enter here and on Form 1116, Part I, or Form 1118, Sch. A (see \ninstructions) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n ▶\n3\n4\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4\n5\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n5\n6 \nSection 965(c) deduction in U.S. dollars from pass-throughs allocable to section 965(a) \ninclusion (see instructions). Enter here and on Form 1116, Part I, or Form 1118, Sch. A .\n ▶\n6\n7\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n7\n8\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n8\n9 \nTaxes deemed paid through pass-throughs. Enter amount from Schedule F, column (l), \nline 16. Also report on Form 1118, Schedule B, Part I, column 3 .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n9\n10\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n10\n11 \nEnter the 2020 Applicable Percentage from pass-throughs. If there are multiple pass-throughs, \nleave this line blank and attach a schedule .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n11\n12\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n12\n13\nReserved .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n13\n14 \nDisallowed foreign taxes through pass-throughs. Attach calculation. See instructions. \nReport amount here and include on Form 1118, Schedule G, Part I, line F \n.\n.\n.\n.\n.\n.\n14\nFor Privacy Act and Paperwork Reduction Act Notice, see the separate instructions.\nCat. No. 71323K\nSchedule H (Form 965) (Rev. 12-2020) \n" ]
f1118sj.pdf	1220 Form 1118 (Schedule J) (PDF)	https://www.irs.gov/pub/irs-pdf/f1118sj.pdf	[ "Schedule J \n(Form 1118) \n(Rev. December 2020)\nAdjustments to Separate Limitation Income (Loss) Categories for \nDetermining Numerators of Limitation Fractions, Year-End Recharacterization Balances, \nand Overall Foreign and Domestic Loss Account Balances\nDepartment of the Treasury \nInternal Revenue Service \n▶ Attach to Form 1118.\nOMB No. 1545-0123 \nFor calendar year 20 \n, or other tax year beginning \n, 20 \n, and ending \n, 20 \nName of corporation \nEmployer identification number \nPart I \nAdjustments to Separate Limitation Income or (Losses) in Determining Numerators of Limitation Fractions (see instructions) \n( ) ( ) ( ) ( )\n( )\n( ) ( ) ( )\n( ) ( )\n( ) ( )\n( ) ( ) ( )\n( )\n( ) ( ) ( ) ( )\n( )\n( ) ( ) ( ) ( ) ( )\n( ) ( ) ( ) ( ) ( )\n( )\n( )\n( )\n( )\n( )\n( )\n(i) \nSection 951A income \n(ii) \nForeign branch income \n(iii) \n Passive category income\n(iv) \nGeneral category income\n(v) \nOther income\n(identify ▶\n)\n(vi) \nU.S. income \n1 \nIncome or (loss) before adjustments \n2 \nAllocation of separate limitation losses: \na Section 951A income\nb Foreign branch income\nc Passive category income\nd\nGeneral category income\ne \n \nOther income (identify ▶\n)\n3 \nSubtotal—Combine lines 1 through 2e. \n4 \nAllocation of overall foreign losses \n5 \nAllocation of domestic losses\n6 \nSubtotal—Combine lines 3 through 5. \n7 \nRecapture of overall foreign losses \n8 \nSubtotal—Combine lines 6 and 7. \n9 \n \nRecharacterization of separate limitation \nincome: \na Section 951A income\nb Foreign branch income\nc Passive category income\nd\nGeneral category income\ne \n \nOther income* (identify ▶\n)\n10 \nRecapture of overall domestic losses\n11 \n \n \n \nNumerator of Limitation Fraction—\nCombine lines 8 through 10. Enter each \nresult here and on Schedule B, Part II, \nline 7, of corresponding Form 1118. \n* Important: See Computer-Generated Schedule J in instructions.\nFor Paperwork Reduction Act Notice, see the Instructions for Form 1118.\nCat. No. 10309U \nSchedule J (Form 1118) (Rev. 12-2020) \n", "Schedule J (Form 1118) (Rev. 12-2020)\nPage 2\nPart II \nYear-End Balances of Future Separate Limitation Income That Must Be Recharacterized (section 904(f)(5)(C)) \n(i) \nSection 951A income \n(ii) \nForeign branch income \n(iii) \n Passive category income\n(iv) \nGeneral category income\n(v) \nOther income\n(identify ▶\n)\n(vi) \nU.S. income \na Section 951A income\nb Foreign branch income\nc Passive category income\nd\nGeneral category income\ne \n \nOther income (identify ▶\n)\nPart III \nOverall Foreign Loss Account Balances (section 904(f)(1)) Complete for each separate limitation income category. \n( ) ( ) ( ) ( ) ( )\n( ) ( ) ( ) ( ) ( )\n \n \n \n \n \n \n1 \nBeginning balance \n2 \nCurrent year additions\n3 \n \nCurrent year reductions (other than \nrecapture) \n4 \nCurrent year recapture (from Part I, line 7)\n5 \n \nEnding balance—Combine lines 1 \nthrough 4. \nPart IV \nOverall Domestic Loss Account Balances (section 904(g)(1)) \n( ) ( ) ( ) ( ) ( )\n \n \n \n \n \n \n1 \nBeginning balance \n2 \nCurrent year additions\n3 \n \nCurrent year reductions (other than \nrecapture) \n4 \nSubtotal—Combine lines 1 through 3.\n5 \nCurrent year recapture (from Part I, line 10) \n6 \nEnding balance—Subtract line 5 from line 4. \n* Important: See Computer-Generated Schedule J in instructions.\nSchedule J (Form 1118) (Rev. 12-2020)\n" ]
f9465sp.pdf	1020 Form 9465 (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/f9465sp.pdf	[ "Formulario 9465(SP)\n(Rev. octubre de 2020) \nDepartment of the Treasury \nInternal Revenue Service \nSolicitud para un Plan de Pagos a Plazos \n▶ Visite www.irs.gov/Form9465SP para obtener las instrucciones y la información más reciente.\n▶ Si presenta este formulario con su declaración de impuestos, \nadjúntelo al frente de su declaración. \nOMB No. 1545-0074\nConsejo: Si adeuda $50,000 o menos, quizás no tenga que presentar el Formulario 9465(SP) y pueda establecer su plan de pagos en línea aun si no \nha recibido una factura de impuestos. Acceda a www.irs.gov/OPA para solicitar un plan de pagos a plazos en línea. Si establece su plan de pagos a \nplazos en línea, el cargo administrativo que usted pagará será menor de lo que sería con el Formulario 9465(SP).\nParte I\nSolicitud para un Plan de Pagos a Plazos\nEsta solicitud es para el (los) Formulario(s) (por ejemplo, el Formulario 1040 o el Formulario 941) ▶\nAnote el (los) año(s) o período(s) tributario(s) (por ejemplo, 2019 o 1 de enero de 2019 a 30 de junio de 2019) ▶\n1a\nPrimer nombre e inicial \nApellido \nNúmero de Seguro Social \nSi es una declaración conjunta, primer nombre e inicial del cónyuge \nApellido del cónyuge \nNúmero de Seguro Social del cónyuge \nDirección actual (número y calle). Si tiene apartado postal sin entrega a domicilio, anote el número del apartado postal. \nNúmero de apartamento \nCiudad, pueblo u oficina de correos, estado y código postal (ZIP). Si es una dirección extranjera, también complete los espacios siguientes (vea las instrucciones).\nNombre del país extranjero\nProvincia/estado/condado extranjero\nCódigo postal extranjero\n1b\nSi ha cambiado de dirección desde la última vez que presentó una declaración de impuestos, marque este recuadro \n.\n.\n.\n.\n.\n ▶\n2 \nNombre de su negocio (tiene que estar fuera de operación)\nNúmero de identificación del empleador (EIN)\n3 \nNúmero telefónico de su casa \nHora más conveniente para llamarle\n4 \nNúmero telefónico de su trabajo \nExtensión \nHora más conveniente para llamarle \n5\nAnote la cantidad total que adeuda tal como aparece en su(s) declaración(es) de impuestos (o notificación(es))\n5\n6 \nSi tiene una cantidad adeudada adicional que no está incluida en la línea 5, anote la cantidad aquí \n(aun si la cantidad adeudada está incluida en un plan de pagos a plazos vigente) .\n.\n.\n.\n.\n.\n6\n7 \nSume las líneas 5 y 6 y anote el resultado .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n7 \n8 \nAnote la cantidad de todo pago que esté incluyendo con esta solicitud. Vea las instrucciones .\n.\n8 \n9 \nCantidad adeudada. Reste la línea 8 de la línea 7 y anote el resultado .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n9\n10\nDivida la cantidad en la línea 9 por 72.0 y anote el resultado .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n10\n11 \n \n \n \na \n \n \n \n \nAnote la cantidad que puede pagar cada mes. Pida mensualidades de la mayor cantidad posible\npara limitar los cargos de intereses y multas, ya que éstos continuarán hasta que pague el saldo \npor completo. Si usted tiene un plan de pagos a plazos vigente, esta cantidad debe representar su\npago propuesto para el saldo total adeudado. Si no indica una cantidad pagadera en la línea \n11a, se le escogerá una mensualidad dividiendo el saldo adeudado en la línea 9 por 72 meses \n11a\nb\nSi la cantidad en la línea 11a es menor que la cantidad en la línea 10 y usted puede incrementar sus\npagos a una cantidad igual o mayor a la cantidad de la línea 10, anote su mensualidad actualizada \n11b\n• Si no puede incrementar su pago en la línea 11b a una cantidad igual a o mayor que la cantidad de la línea 10, marque \nel recuadro. Además, complete y adjunte el Formulario 433-F(SP), Declaración de Ingresos y Gastos\n.\n.\n.\n.\n.\n.\n.\n• Si la cantidad en la línea 11a (u 11b, si le aplica) es igual a o mayor que la cantidad en la línea 10 y la cantidad adeudada es \nmayor de $25,000 pero no supera $50,000, entonces no tendrá que completar el Formulario 433-F(SP). No obstante, si no \ncompleta el Formulario 433-F(SP), tendrá que completar la línea 13 o 14.\n• Si la cantidad en la línea 9 es mayor de $50,000, complete y adjunte el Formulario 433-F(SP).\n12\nAnote el día del mes en el cual desea efectuar su pago mensual. No anote ninguna fecha posterior al 28 del mes\n12\n13 \nSi desea hacer pagos mediante retiro electrónico de fondos de su cuenta corriente, vea las instrucciones y complete las líneas\n13a y 13b. Ésta es la manera más fácil de hacer los pagos y garantiza que se harán a tiempo. \n▶\na\n▶\nb\nNúmero de cuenta \nAutorizo al U.S. Treasury (Departamento del Tesoro de los Estados Unidos) y a su agente financiero debidamente autorizado para que tramiten ante la ACH una transacción de retiro \nelectrónico de fondos mensual de mi cuenta en la institución financiera indicada en este formulario para pagar las cantidades de los impuestos federales que adeudo. Además, autorizo a \ndicha institución financiera para que haga un cargo a mi cuenta por la cantidad de dicho pago mensual. Esta autorización quedará en pleno vigor hasta que yo notifique al agente \nfinanciero del Departamento del Tesoro de los EE.UU. para que éste termine la autorización. Para revocar el pago, tengo que comunicarme con el agente financiero del Departamento del \nTesoro de los EE.UU. al 1-800-829-1040 a más tardar 14 días laborables antes de la fecha de liquidación del pago. También autorizo a las instituciones financieras que participan en la \ntramitación de los pagos electrónicos de impuestos para que reciban información confidencial necesaria para responder a preguntas y resolver toda duda relacionada con dichos pagos. \nc \n \nSólo para contribuyentes de bajos ingresos. Si no puede hacer pagos electrónicos a través de un instrumento de\ndébito al proveer su información financiera en las líneas 13a y 13b, marque este recuadro y su cargo administrativo le \nserá reembolsado una vez haya realizado todos los pagos de su acuerdo. Vea las instrucciones .\n.\n.\n.\n.\n.\n.\n.\n14\nSi desea hacer pagos por medio de deducción de nómina, marque este recuadro y adjunte un Formulario 2159(SP) completado \nAl firmar y presentar este formulario, yo autorizo al IRS a contactar a terceros y a divulgar mi información tributaria a terceros para poder tramitar esta solicitud y administrar el \nacuerdo durante la vigencia de éste. También acepto los términos de este acuerdo, según provistos en las instrucciones, de éste ser aprobado por el Servicio de Impuestos Internos.\nSu firma \nFecha \nFirma de su cónyuge. Si presentaron una declaración conjunta, ambos tienen que firmar. \nFecha \nPara el Aviso sobre la Ley de Confidencialidad de Información y la Ley de Reducción \nde Trámites, vea las instrucciones. \nCat. No. 20606M \nFormulario 9465(SP) (Rev. 10-2020) \nNúmero de circulación \n", "Formulario 9465(SP) (Rev. 10-2020) \nPágina 2 \nParte II\nInformación Adicional\nComplete esta parte sólo si estas tres situaciones a continuación le aplican:\n1. Ha incumplido un plan de pagos a plazos durante los últimos 12 meses;\n2. La cantidad que adeuda es mayor de $25,000 pero no supera $50,000; y\n3. La cantidad en la línea 11a (u 11b, si le aplica) es menor que la cantidad de la línea 10.\nNota: Si adeuda más de $50,000, también complete y adjunte el Formulario 433-F(SP).\n15\n¿En qué condado está su residencia principal?\n16a\nEstado civil:\nSoltero. Ignore la pregunta 16b y pase a la pregunta 17.\nCasado. Pase a la pregunta 16b.\nb\n¿Comparte usted gastos del hogar con su cónyuge?\nSí.\nNo. \n17\n¿Cuántos dependientes podrá reclamar en la declaración de impuestos de este año? \n.\n17\n18\n¿Cuántas personas en su hogar tienen 65 años de edad o más? \n.\n.\n.\n.\n.\n.\n.\n.\n18\n19\n¿Cada cuánto le pagan?\nUna vez a la semana.\nUna vez cada 2 semanas.\nUna vez al mes. \nDos veces al mes. \n20\n¿Cuál es su ingreso neto cada período de pago (después de deducciones)? .\n.\n.\n.\n. \n20 $\nNota: Complete las líneas 21 y 22 si está casado y cumple ciertos requisitos (vea las instrucciones). Si no está casado, pase a \nla línea 23.\n21\n¿Cada cuánto le pagan a su cónyuge?\nUna vez a la semana.\nUna vez cada 2 semanas.\nUna vez al mes. \nDos veces al mes.\n22\n¿Cuál es el ingreso neto de su cónyuge cada período de pago (después de deducciones)?\n22 $\n23\n¿Cuántos vehículos tiene usted?\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n23\n24\n¿Para cuántos autos tiene que hacer pagos mensuales? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n24\n25a\n¿Tiene usted seguro médico?\nSí. Pase a la pregunta 25b. \nNo. Ignore la pregunta 25b y pase a la pregunta 26a. \nb\n¿Se deducen las primas del seguro médico de su cheque de paga?\nSí. Ignore la pregunta 25c y pase a la pregunta 26a. \nNo. Pase a la pregunta 25c.\nc\n¿De qué cantidad son las primas mensuales de su seguro médico?.\n.\n.\n.\n.\n.\n.\n.\n25c $\n26a\n¿Hace usted pagos por orden judicial?\nSí. Pase a la pregunta 26b.\nNo. Pase a la pregunta 27. \nb\n¿Se deducen de su cheque de paga los pagos hechos por orden judicial?\nSí. Pase a la pregunta 27. \nNo. Pase a la pregunta 26c. \nc\n¿De qué cantidad son los pagos que usted hace cada mes por orden judicial? .\n.\n.\n.\n26c $\n27 \nSin incluir los pagos de manutención de hijos y dependientes por orden judicial, ¿cuánto \npaga en gastos del cuidado de hijos o dependientes cada mes? .\n.\n.\n.\n.\n.\n.\n.\n.\n27 $\nFormulario 9465(SP) (Rev. 10-2020) \n" ]
fw10.pdf	1020 Form W-10 (PDF)	https://www.irs.gov/pub/irs-pdf/fw10.pdf	[ "Form W-10\n(Rev. October 2020) \nDepartment of the Treasury \nInternal Revenue Service \nDependent Care Provider’s Identification and Certification \n▶ Do NOT file Form W-10 with your tax return. Instead, keep it for your records. \n▶ Go to www.irs.gov/FormW10 for the latest information.\nPart I \nDependent Care Provider’s Identification (see instructions) \nPlease \nPrint \nor \nType \nName of dependent care provider \nAddress (number, street, and apt. no.) \nCity, state, and ZIP code \nProvider’s taxpayer identification number \nIf the above number is a social security \nnumber, check here ▶\n.\n.\n.\n.\n.\n.\nCertification and Signature of Dependent Care Provider. Under penalties of perjury, I, as the dependent care provider, certify that my \nname, address, and taxpayer identification number shown above are correct. \nPlease \nSign \nHere\nDependent care provider’s signature \nDate \nPart II \nName and Address of Person Requesting Part I Information (see instructions) \nName, street address, apt. no., city, state, and ZIP code of person requesting information \nGeneral Instructions \nSection references are to the Internal Revenue Code.\nPurpose of form. You must get the information shown in Part I \nfrom each person or organization that provides care for your child or \nother dependent if: \n1. You plan to claim a credit for child and dependent care \nexpenses on Form 1040 or 1040-SR, or \n2. You receive benefits under your employer’s dependent care \nplan. \nIf either 1 or 2 above applies, you must show the correct name, \naddress, and taxpayer identification number (TIN) of each care \nprovider on Form 2441, Child and Dependent Care Expenses. \nYou may use Form W-10 or any of the other sources listed under \nDue diligence below to get this information from each provider. \nPenalty for failure to furnish TIN. TINs are needed to carry out the \nInternal Revenue laws of the United States. Section 6109(a) \nrequires a provider of dependent care services to give to you a \nvalid TIN, even if the provider isn’t required to file a return. The IRS \nuses the TIN to identify the provider and verify the accuracy of the \nprovider’s return as well as yours. \nA care provider who doesn’t give you a correct TIN is subject to a \npenalty for each failure unless the failure is due to reasonable cause \nand not willful neglect. This penalty doesn’t apply to an organization \ndescribed in section 501(c)(3). See Tax-exempt dependent care \nprovider, later. \nIf incorrect information is reported. You won’t be allowed the tax \ncredit or the exclusion for employer-provided dependent care \nbenefits if: \n• You report an incorrect name, address, or TIN of the provider on \nyour Form 2441; and \n• You can’t establish, to the IRS upon its request, that you used \ndue diligence in trying to get the required information. \nDue diligence. You can show due diligence by getting and keeping \nin your records any one of the following. \n• A Form W-10 properly completed by the provider. \n• A copy of the provider’s social security card.\n• A recently printed letterhead or printed invoice that shows the \nprovider’s name, address, and TIN. \n• If the provider is your employer’s dependent care plan, a copy of \nthe statement provided by your employer under the plan. \n• If the provider is your household employee and he or she gave \nyou a properly completed Form W-4, Employee’s Withholding \nCertificate, to have income tax withheld, a copy of that Form W-4. \nIf your care provider doesn’t comply with your request for one of \nthese items, you must still report certain information on your Form \n2441. For details, see the Instructions for Form 2441. \nSpecific Instructions \nPart I \nThe individual or organization providing the care completes this \npart. \nEnter the provider’s name, address, and TIN. For individuals and \nsole proprietors, the TIN is a social security number (SSN). But if the \nprovider is a nonresident or resident alien who doesn’t have and \nisn’t eligible to get an SSN, the TIN is an IRS individual taxpayer \nidentification number (ITIN). For other entities, it is the employer \nidentification number (EIN). If the provider is exempt from federal \nincome tax as an organization described in section 501(c)(3), see \nTax-exempt dependent care provider below. \nHow to get a TIN. Providers who don’t have a TIN should apply for \none immediately. To apply for an SSN, get Form SS-5, Application \nfor a Social Security Card, from your local Social Security \nAdministration office. To apply for an ITIN, get Form W-7, \nApplication for IRS Individual Taxpayer Identification Number, from \nthe IRS. To apply for an EIN, get Form SS-4, Application for \nEmployer Identification Number, from the IRS. \nNote: An ITIN is for tax use only, and may expire under certain \nconditions. It doesn’t entitle the individual to social security benefits \nor change his or her employment or immigration status under U.S. \nlaw. For details, see the Instructions for Form W-7. \nTax-exempt dependent care provider. A provider who is a tax-\nexempt organization described in section 501(c)(3) and exempt \nunder section 501(a) isn’t required to supply its TIN. Instead, the \nprovider must complete the name and address lines and write “tax-\nexempt” in the space for the TIN. Generally, an exempt 501(c)(3) \norganization is one organized and operated exclusively for religious, \ncharitable, scientific, testing for public safety, literary, or educational \npurposes, or for the prevention of cruelty to children or animals. \nPart II \nComplete this part only if you are leaving the form with the \ndependent care provider to return to you later. \nCat. No. 10437N \nForm W-10 (Rev. 10-2020) \n" ]
f8981.pdf	1020 Form 8981 (PDF)	https://www.irs.gov/pub/irs-pdf/f8981.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
f8982.pdf	1020 Form 8982 (PDF)	https://www.irs.gov/pub/irs-pdf/f8982.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
p5346.pdf	1020 Publ 5346 (PDF)	https://www.irs.gov/pub/irs-pdf/p5346.pdf	[ "Publication 5346\nPartnership Request for Modification of Imputed \nUnderpayments Under IRC Section 6225(c)\nInstructions for Form 8980\nPublication 5346 (10-2020) Catalog Number 72774P Department of the Treasury Internal Revenue Service www.irs.gov\nGeneral Instructions\nElectronic Submission of Form 8980\nInternal Revenue Code (IRC) section 6241(10), in part, gives the IRS authority to require electronic filing of anything required to be filed or submitted \nunder section 6225(c). Please submit Form 8980, attachments, and related forms electronically. Refer to the BBA website (irs.gov/bbapartnerships) for \nsteps and instructions for electronic submission.\nBe sure to download and complete the latest version of the fillable forms available from irs.gov/forms-instructions. Any earlier version of the \nforms cannot be submitted electronically and will be rejected. Also, see “Important Tips for Electronic Submission” below.\nIf you are having difficulty downloading or opening the PDF form, it may be because of the browser you are using. Check that “Adobe” is set \nas the program that opens the PDF, by right clicking on any PDF file on your computer. Once you right click, select “properties.” If “Adobe” \nisn’t the program that the form “opens with”, change it to “Adobe”. \nImportant Tips for Electronic Submission\n• \nDownload and complete the latest version of the fillable forms available from irs.gov/forms-instructions. Any earlier version of the forms cannot \nbe submitted electronically and will be rejected. \n• \nThe fillable form has mandatory fields that must be completed in order for the form to be accepted when it is submitted. Mandatory fields \nare generally outlined in red boxes on the fillable form. If you do not complete all mandatory fields on the fillable form, you will get a pop-up \nmessage stating that you have not completed all of the mandatory fields. Please note: ALL FORMS LISTED BELOW AS “PRIMARY” OR \n“RELATED” MUST BE SUBMITTED IN THEIR FILLABLE FORMAT, not printed and scanned to create a PDF file. The attachments, \nsignature files, and “Manual signature” forms listed below may be printed and scanned to create a PDF or other type of document in \norder to upload for electronic submission.\n• \nName fields: Do not enter double blank spaces or punctuation.\n• \nTaxpayer ID Number (TIN) fields: \no\t\nFor TIN fields which can be either an Employer Identification Number (EIN) or Social Security Number (SSN), be sure to enter a \ndash when entering an EIN (Example: XX-XXXXXXX), and two dashes when entering an SSN (Example: XXX-XX-XXXX). \no\t\nFor fields that stipulate an EIN or SSN, you do not need to enter the dashes, as the fillable form will appropriately format the number \nand automatically include the dash/dashes.\n• \nU. S. Zip Code fields: U.S. Zip Code fields should be entered as either 5 or 9 numeric digits, no dashes. The fillable form will automatically \ninclude a dash if 9 numeric digits are entered.\n• \nForm 8980, Attachments to Form 8980, and Form 8980 related forms (Form 8982, Form 8983, and Form 15028): \no\t\nDo not password protect or encrypt attachments.\no\t\nThe file name should be a unique, meaningful name and description. The following file name requirements must be followed when \nnaming files:\nAllowed:\n Alpha (A-Z);\n Numeric (0-9);\n Hyphen/dash (-);\n Underscore (_);\n Maximum of 50 characters (including the file extension);\n Allowed file extensions:.doc,.docx,.pdf,.xls,.xlsx,.zip;\n Use unique filenames. For example, you cannot have two attachments as follows: “form.pdf” and “form.doc” included in the same \nsubmission. \n Avoid naming files; “Other”, “PDF Attachment”, “Miscellaneous Information”, or any other generic term.\nNot Allowed:\n Blank spaces\n Consecutive dashes or underscores\n Special characters (other than non-consecutive dashes or underscores)\n• \nWhen electronically submitting Form 8980 (Primary form) and any required Related Forms (Forms 8982, Forms 8983, and Form \n15028), the following categories of forms and attachments are possible:\no\t\nPrimary form: Form 8980\no\t\nForm 8980 Attachments (includes statements and schedules which provide further information to information requested in Form 8980)\no\t\nRelated form: Form 8982\no\t\nForm 8982 Signature files (Each Form 8982 submitted must have an associated signature file that includes a scanned image of partner \nsignature page)\no\t\nForm 8982 Attachments (includes statements and schedules when additional space is needed beyond form capacity)\n", "2\no\t\nRelated Form: Form 8983\no\t\nForm 8983 Signature files (Each Form 8983 submitted must have an associated signature file that includes a scanned image of partner \nsignature page)\no\t\nForm 8983 Attachments (includes required statements and schedules as applicable and when additional space is needed beyond form \ncapacity)\no\t\nRelated Form: Form 15028\no\t\nForm 15028 Attachments (when additional space is needed beyond form capacity) \no\t\nOther forms relating to the Modification process that can be submitted electronically as stand-alone forms:\n Form 8981\n Form 8984 \n Form 15027 (agreement)\n Form 14726\n• \nModification-related Form Signature Requirements: Electronically submitted forms have different signature requirements depending on the \nform. The following is a summary of the form signature methods and submission formats: \nForm\nSigned By\nSignature Method\n8980\nPartnership Representative\nPIN signature\n8982\nPartner & Partner’s spouse (if applicable)\nManual signature – separate file\n8983\nPartner\nManual signature – separate file\n15028\nPartnership Representative\nPIN signature\n8981\nPartnership Representative\nPIN signature\n8984\nPartnership Representative\nManual signature – no separate file\n15027\nPartnership Representative\nManual signature – no separate file\n14726\nPartnership Representative\nManual signature – no separate file\nExplanation of Signature Methods:\nPIN signature = 5-digit PIN signature is transmitted as part of the form when the form is electronically submitted. This is the PIN that is self-\nselected during the Transmitter Control Code (TCC) application step of the multi-step process for electronic submission (go to https://www.irs.\ngov/bbapartnerships for the complete steps and instructions for electronic submission). If you didn’t select a PIN or don’t remember the PIN \nselected, you must select or change the PIN before signing and submitting the form. The “typed” name of the person signing the form must \nexactly match the name entered during the TCC application step for electronic submission. For example, if the name entered during the TCC \napplication step is John T. Smith, the typed name on the form must be John T. Smith, not John Smith, JT Smith, etc.\nManual signature – separate file = Requires a separate file to be uploaded (in addition to the completed fillable form) that includes the \nsignature page with the scanned image of the signature, referred to as a “signature file”.\nManual signature – no separate file = The form is completed, manually signed, and then scanned to create a PDF file to upload for \nelectronic submission.\n• \nSuccessful Electronic Submission = Receipt ID: When you have successfully submitted your forms electronically, a “Receipt ID Number” \nwill be displayed along with a list of forms that have been submitted. You should print and keep the Receipt ID page displayed. You need \nthe Receipt ID in order to check the status of your form submission. If the submission was “Rejected”, you will receive the reason(s) for the \nrejection so that you can fix the forms and resubmit them. If the status is “Accepted”, there is nothing further you need to do. \nPurpose of Form 8980\nSection references are to the Internal Revenue Code (IRC) unless otherwise noted.\nForm 8980 is submitted by a partnership to request the modification of an imputed underpayment under section 6225(c). An imputed underpayment \nis reported to a partnership in a notice of proposed partnership adjustment (NOPPA). Additionally, Form 8980 is also used by a partnership which is \napplying certain permitted modifications to an imputed underpayment included in the filing of an Administrative Adjustment Request (AAR). In the case of \nan AAR which includes modifications to an imputed underpayment, the partnership should complete and attach Form 8980 (including all required Form \n8980 supporting forms and attachments, and any supporting documents) to the AAR when filed. Note: AARs that include Form 8980 must be filed at the \nInternal Revenue Service Center location where the partnership’s original return was filed.\nModification Request Not for Disputed Partnership Issues. A request for modification is a request to modify an imputed underpayment and is not \na request to appeal or modify partnership adjustments. The Office of Appeals handles formal protests of any proposed partnership adjustments and \nimputed underpayment computations when requested prior to the issuance of the NOPPA. For further information on the Appeals process and filing a \nformal protest prior to receiving a NOPPA, see Publication 5, Your Appeal Rights and How To Prepare a Protest If You Don’t Agree.\nWho Must Submit\nModification Request of a NOPPA Imputed Underpayment. A partnership choosing to request modification of a proposed imputed underpayment \nreported in a NOPPA should use Form 8980 to request the modification. The partnership representative (PR) should complete and sign Form 8980 \nand include all required Form 8980 supporting forms and attachments and any supporting documents when Form 8980 is submitted. The IRS will \nacknowledge your request and will contact you if additional information is required in order to evaluate your request and make a determination.\nModification of Adjustments That Do Not Result in an Imputed Underpayment. If the imputed underpayment calculation in the NOPPA results in \nan amount that is zero or less than zero, or if there are net negative adjustments that are excluded from the calculation of the imputed underpayment, \nmodification may be requested with respect to the underlying adjustments under the following types of modification and using the appropriate Part of \nItem E of Form 8980:\n• \nPartner amended returns (use Part I);\n• \nPartner alternative procedure (use Part I);\n", "3\n• \nModification of the number and composition of the imputed underpayments (use Part V);\n• \nClosing agreements (use Part VII for partner closing agreements, and use Part IX for a source partnership closing agreement); or\n• \nOther Modifications, if applicable (use Part IX).\nModifications Applied to an Imputed Underpayment Reported in an Administrative Adjustment Request (AAR). Form 8980 is also used to report \nto the IRS, any permitted modifications that are being applied to an imputed underpayment reported in an AAR. The PR should complete and sign Form \n8980, including all required Form 8980 supporting forms and attachments and any supporting documents, and include it with the AAR when filed. AARs \nmust be filed at the IRS Service Center where the partnership’s original return was filed.\nOne Form 8980 Per Reviewed Year: If a partnership is requesting modification for more than one reviewed year, a Form 8980 should be completed and \nsubmitted for each reviewed year. Each Form 8980 pertains to a particular partnership and a particular reviewed year.\nPartnership Responsibility to Provide Information to Partners. The failure of the partnership to provide all necessary information to the partner in \norder for the partner to fulfill its requirements pertaining to a particular requested modification may result in the IRS’s denial, in whole or in part, of the \npartnership’s request for modification. For all modification requests involving one or more relevant partners’ actions affecting the source partnership’s \nmodification request, the PR must provide to each relevant partner their distributive share of all proposed partnership adjustments set forth in the \npartnership’s NOPPA, regardless of whether such adjustments resulted in an imputed underpayment(s). This information must also be provided by the \nPR on Form 8980, Item C, Allocation of Adjustments Relevant to Modification. The PR should provide all necessary information with regard to each \nadjustment allocation in order for the partner to fulfill the requirements pertaining to a particular requested modification. Such information includes a \ndescription of each positive and negative adjustment, grouping, subgrouping, and whether or not the adjustment was included in the general or a specific \nimputed underpayment.\nWhen to Submit\nModification Request of a NOPPA Imputed Underpayment. Under section 6225(c)(7), a partnership has 270 calendar days from the mail date of the \npartnership’s NOPPA to request modification. Form 8980, along with all required supporting forms and attachments should be submitted within this 270-\nday modification submission period. This period may be extended if it is requested by the partnership and approved by the IRS. See “Extension of the \nModification Submission Period” below.\nModifications to an Imputed Underpayment Included in an Administrative Adjustment Request (AAR). If filing an AAR with modifications, refer \nto the instructions in the relevant AAR forms regarding the allowable time period to file an AAR. Form 8980, including all required attachments and \nsupporting documentation, should be attached to an AAR when it is filed if such AAR includes any permitted modifications that are being applied to the \nimputed underpayment reported in the AAR. Permitted modifications to an imputed underpayment in an AAR include: modifications regarding tax-exempt \npartners; the applicable highest tax rate; certain passive activity losses of specified partners or qualified relevant partners of publicly traded partnerships; \nthe limitation or restriction in the grouping of adjustments; qualified investment entity partners; foreign partner tax treaty modification and statutory \nexemptions; and other modifications (if appropriate). Modifications for partner amended returns, partner alternative procedure, and closing agreements \nare not permitted in an AAR. AARs must be filed at the Internal Service Center location where the partnership’s original return was filed.\nExtension of the Modification Submission Period. If the partnership’s 270-day period from the NOPPA mail date has not expired and the partnership \nneeds additional time to submit a modification request, to fully complete a timely submitted Form 8980 modification request, to provide the required \nsupporting documents relative to a modification request, or to correct a previously submitted modification request, the 270-day period under section \n6225(c)(7) may be extended, if it is requested by the partnership and approved by the IRS. Use Form 8984, Extension of the Taxpayer Modification \nSubmission Period Under Section 6225(c)(7), to request an extension of the 270-day modification submission period. Such request, if made, must be \nsubmitted and approved, prior to the expiration of the 270-day period. Form 8984 should be submitted electronically.\nWhat to Submit with Form 8980 \nAll related forms (when required) such as Forms 8982, 8983, and 15028, and any required attachments to Form 8980 should be submitted along with \nForm 8980. The related forms and required supporting attachments will depend upon the type(s) of modifications being requested, or in the case of \nan AAR, the permitted modifications being applied to the imputed underpayment in the AAR. See the specific instructions for each type of modification \nrequested for the required related forms and supporting attachments that needs to be included with Form 8980 when submitted.\nWho Must Sign\nThe partnership representative (PR) of the source partnership requesting modification, or applying permitted modifications in the case of an AAR; must \nsign Form 8980, Item F.\nWhere to Submit\nSubmitting Form 8980 pursuant to receipt of a NOPPA. You must upload the completed fillable version of the form. (Do not print, scan, and upload \nForm 8980). See “Electronic Submission of Form 8980” at the beginning of these instructions, for additional information.\nSubmitting Form 8980 with an AAR. You should attach the completed form with the AAR being filed. AARs must be filed at the IRS Service Center \nwhere the partnership’s original return was filed. Refer to the instructions in the relevant AAR forms.\nBBA Partner Payments Related to Requested Modifications\nAll partner payments relating to modifications that will be requested must be properly identified as a partner payment under BBA modification. IRS offers \nseveral payment options. Partners can pay online or by phone, mobile device, cash (maximum $1,000 per day and per transaction), check, or money \norder. Go to IRS.gov/Payments for payment options. However partners choose to pay, they must identify their payment by selecting “Partner Payment \n(Pymnt) for BBA Modification”. If partners choose to mail a tax payment, they must make their check or money order payable to “United States \nTreasury” for the full amount due. On their payment, they must put their name, current address, daytime phone number, and SSN/TIN. If they are a joint \nfiler, enter the SSN shown first on their return. Also, include the tax year and description as follows: “Modification [Insert Tax Year] Form [Insert Form \nNumber]”. To help process the payment, enter the amount on the right side of the check like this: $XXX.XX. Do not use dashes or lines (for example, do \nnot enter “$XXX-“ or “$XXXxx100”).\n", "4\nWaiver of the Modification Submission Period\nIf the partnership has submitted a complete and accurate Form 8980 along with all required attachments and supporting documentation and does \nnot need the full 270-day period (or longer period if an extension was previously approved) to submit supplemental modification requests or provide \nadditional information, the partnership may request to waive the remainder of the modification submission period by submitting Form 8981, Waiver of the \nPeriod Under IRC Section 6231(b)(2)(A) and Expiration of the Period for Modification Submissions Under IRC Section 6225(c)(7). If the IRS approves \nthe waiver, you will be notified in writing. An approved Form 8981 will allow the IRS to complete its evaluation of the partnership’s modification request, \nnotify the partnership of the modification acceptance or denial, and issue the notice of final partnership adjustment (FPA) earlier than if a waiver is not \nrequested. Form 8981 should be submitted electronically.\nSubstantiation of Facts Supporting a Modification Request\nA partnership requesting modification must demonstrate to the satisfaction of the IRS that any modification requested is appropriate and accurate. The \npartnership bears the burden of providing all documents required to establish the appropriateness and accuracy of a modification request. The IRS may \ndeny modification, in whole or in part, if the partnership fails to provide sufficient evidence of the appropriateness and accuracy of a modification request.\nNotification of Modification Acceptance or Denial. All modification requests pursuant to a NOPPA must be approved by the IRS. The IRS will notify \nthe partnership in writing of the modification determination.\nAppeal of Modification Determination. Regarding modification requests pursuant to a NOPPA, once the partnership is notified, in writing, regarding \nthe details of approved, partially approved, and denied modifications, along with the computation of the resulting modified imputed underpayment(s), \nif the partnership disagrees with the IRS’ determination, the partnership may first request a conference with the group manager. If there is still \ndisagreement after the conference, the partnership can appeal its case to the IRS Independent Office of Appeals. The modification determination \nnotification letter (Letter 5975) will provide information regarding what to do if you disagree with the determination.\nDefinitions\n270-Day Modification Submission Period Expiration Date refers to the end of the period defined in section 6225(c)(7) during which an audited \npartnership may request modification (including the submission of all required supporting documents). This period is 270 calendar days from the date the \nNOPPA is mailed. The 270-Day Modification Submission Period Expiration Date is included on the top right section of the NOPPA Letter 5892/5892-A \nreceived by the partnership/partnership representative. The submission period may be extended if requested by the partnership (using Form 8984) and \napproved by the IRS.\nAdjustment year means the partnership taxable year in which:\n(i)\t\nIn the case of an adjustment pursuant to the decision of a court in a proceeding brought under section 6234, such decision becomes final;\n(ii)\t\nIn the case of an administrative adjustment request (AAR) under section 6227, such AAR is filed; or\n(iii)\t\nIn any other case, a notice of final partnership adjustment is mailed under section 6231 or, if the partnership waives the restrictions under \nsection 6232(b) (regarding limitations on assessments), the waiver is executed by the IRS.\nAdjustment year partners means any person who held an interest in a partnership at any time during the adjustment year.\nAdjustments That Do Not Result in an Imputed Underpayment occur if: (i) After grouping, subgrouping, and netting the adjustments, the result of \nnetting with respect to any grouping or subgrouping that includes a particular partnership adjustment is a net negative adjustment; or (ii) The imputed \nunderpayment calculation results in an amount that is zero or less than zero. Any adjustment that does not result in an imputed underpayment is taken \ninto account by the partnership in the adjustment year, except if an AAR is being filed. Modification may be requested with respect to such adjustments \nunder the following types of modification: Amended returns, Alternative procedure, Number and composition of the imputed underpayments, Closing \nagreements, or, if applicable Other Modifications. Use the appropriate Part of Form 8980, Item E, to request such modification.\nAlternative Procedure refers to the procedure under section 6225(c)(2)(B) whereby a relevant partner fulfills all of the requirements under section \n6225(c)(2), except that the partner does not file an amended return. If this modification is requested by the partnership, Form 8982 is a required related \nform to Form 8980. Therefore, in addition to meeting the requirements of the alternative procedure, the partner must also complete and sign Form 8982 \nand provide it to the PR. The PR must submit Form 8982 (as a related form) when Form 8980 is submitted. See Form 8980, Item E, Part I and the \nassociated specific line instructions, along with Form 8982 and instructions.\nClosing Agreement for this purpose is an agreement entered into by the IRS and the partnership or any relevant partner, or both, if appropriate, \npursuant to section 7121. See Form 8980, Item E, Part VII and the associated specific line instructions.\nDirect partner means any person that holds a direct interest in a partnership, and not through another entity. A direct partner can also be a relevant \npartner.\nFirst affected year is the taxable year of the partner that includes the end of the partnership’s reviewed year.\nGeneral Imputed Underpayment is calculated based on all adjustments (other than adjustments that do not result in an imputed underpayment) that \nare not taken into account to determine a specific imputed underpayment. If there is only one imputed underpayment in an administrative proceeding, it \nis a general imputed underpayment.\nGrouping means placing partnership adjustments into one of four groupings: reallocation, residual, creditable expenditure, and credit. For partnerships \nunder examination (and prior to any requested and approved modifications), the grouping of each proposed partnership adjustment is shown on Form \n14792 received by the partnership.\nImputed Underpayment is an amount determined, in accordance with sections 6225, 6226, 6227 and the Regulations thereunder.\nIndirect partner means any person who has an interest in a partnership through their interest in one or more pass-through partners or through a wholly-\nowned entity disregarded as separate from its owner for federal tax purposes. An indirect partner can also be a relevant partner.\nModification refers to the process of the source partnership requesting and obtaining modification to a proposed imputed underpayment or partnership \nadjustment that that does not result in an imputed underpayment set forth in a NOPPA pursuant to the provisions in section 6225(c) and applicable \nRegulations. Modification for an AAR refers to the partnership applying certain permitted modifications to an imputed underpayment pursuant to \napplicable Regulations.\nModification Amended Return is an amended return filed by a relevant partner of a source partnership and takes into account all of the partnership \nadjustments properly allocable to such partner. A modification amended return includes a partner amended return for the partner’s first affected year, and \nall modification years. In order to meet the requirement under IRC section 6225(c)(2), the modification amended return(s) filed by a partner must include \nthe payment of all tax, penalties, additions to tax, and interest due as a result of taking into account all partnership adjustments properly allocated to \n", "5\nthe partner. If this modification is requested by the partnership, Form 8982 is a required related form to Form 8980. Therefore, in addition to filing the \nmodification amended return, the partner must also complete and sign Form 8982 and provide it to the PR. The PR must submit Form 8982 (as a related \nform) when Form 8980 is submitted. See Form 8980, Item E, Part I and the associated specific line instructions, along with Form 8982 and instructions.\nModification year is any taxable year with respect to which any tax attribute of the relevant partner is affected by reason of taking into account the \nrelevant partner’s distributive share of all partnership adjustments in the first affected year. A modification year may be a taxable year before or after the \nfirst affected year, depending on the effect on the relevant partner’s tax attributes from taking into account the relevant partner’s distributive share of the \npartnership adjustments in the first affected year. See Form 8982 and instructions for more information.\nNotice of Proposed Partnership Adjustment (NOPPA) is a notice of proposed partnership adjustment under section 6231(a)(2), and includes Letters \n5892 or 5892-A and Form 14792, Partnership Examination Changes, Imputed Underpayment Computation and Partnership Level Determinations as to \nPenalties, Additions to Tax and Additional Amounts.\nPartnership adjustment means any adjustment to a partnership-related item as defined in applicable Regulations and includes any portion of a \npartnership adjustment.\nPartnership-partner means a partnership that holds an interest in another partnership.\nPass-through partner means a pass-through entity that holds an interest in a partnership. A pass-through entity is:\n• \nA partnership required to file a return under section 6031(a);\n• \nAn S corporation;\n• \nA trust (other than a wholly-owned trust disregarded as separate from its owner for federal tax purposes); and\n• \nA decedent’s estate.\nFor this purpose, a pass-through entity is not a wholly-owned entity disregarded as separate from its owner for federal tax purposes.\nPublicly Traded Partnership is defined in section 469(k)(2) and means any partnership if -- interests in such partnership are traded on an established \nsecurities market, or interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof). A publicly traded \npartnership may request modification under IRC section 6225(c)(5) regarding specified passive activity losses of specified partners and qualified relevant \npartners pertaining to the publicly traded partnership’s activity. If such modification is requested by the partnership, Form 15028 must be completed and \nsigned by the PR of the partnership and submitted (as a related form) when Form 8980 is submitted. See Form 8980, Item E, Part IV and the associated \nspecific line instructions, along with Form 15028 and instructions.\nQualified Investment Entity is an entity defined under section 860(b), which includes both a regulated investment company (RIC) and a real estate \ninvestment trust (REIT). See Form 8980, Item E, Part VI and the associated specific line instructions.\nQualified Relevant Partner means a relevant partner that meets the requirements to be a specified partner, for each year beginning with the first \naffected year through the most recent year for which the publicly traded partnership has filed a return under section 6031. An indirect partner of the \npublicly traded partnership if it meets the requirements of a qualified relevant partner, except for being a direct partner of the publicly traded partnership \nrequesting modification, may also be a qualified relevant partner.\nRelevant partner means any person for whom modification is requested by the source partnership that is:\n• \nA reviewed year partner, including any pass-through partner, except for any reviewed year partner that is a wholly-owned entity disregarded as \nseparate from its owner for federal tax purposes; or\n• \nAn indirect partner except for any indirect partner that is a wholly-owned entity disregarded as separate from its owner for federal tax \npurposes.\nReviewed year means the partnership’s taxable year to which a partnership adjustment relates.\nReviewed year partner means any person who held an interest in a partnership at any time during the reviewed year.\nSource partnership means the partnership under examination that is requesting modification of an imputed underpayment under section 6225(c), or a \npartnership filing an AAR to report an imputed underpayment for which it is applying permitted modifications to such imputed underpayment.\nSpecific Imputed Underpayment may be designated by the IRS, with respect to adjustments to a partnership-related item or items that were allocated \nto one partner or a group of partners that had the same or similar characteristics or that participated in the same or similar transaction or on such other \nbases as the IRS determines properly reflects the facts and circumstances. The IRS may designate more than one specific imputed underpayment with \nrespect to any partnership taxable year. In addition, a partnership may request one or more specific imputed underpayments, as a modification. See \nForm 8980, Item E, Part V and the associated specific line instructions for more information.\nSpecified Partner is a person that for each taxable year beginning with the first affected year through the person’s taxable year in which or with which \nthe partnership adjustment year ends that satisfies the following three requirements:\n(A)\t\nThe person is a partner of the publicly traded partnership requesting modification;\n(B)\t\nThe person is an individual, estate, trust, closely held C corporation, or personal service corporation; and\n(C)\t\nThe person has a specified passive activity loss with respect to the publicly traded partnership.\nSpecified Passive Activity Loss means, with respect to any specified partner or qualified relevant partner of a publicly traded partnership, the carryover \namount which is the lesser of the section 469(k) passive activity loss of that partner which is separately determined with respect to such partnership:\n(A)\t\nAt the end of the first affected year (affected year loss); or\n(B)\t\nAt the end of:\n(1)\t\nThe specified partner’s taxable year in which or with which the adjustment year of the partnership ends, reduced to the extent any such \npartner has utilized any portion of its affected year loss to offset income or gain relating to the ownership or disposition of its interest in \nsuch publicly traded partnership during either the adjustment year or any other year; or\n(2)\t\nIf the adjustment year has not yet been determined, the most recent year for which the publicly traded partnership has filed a return under \nsection 6031.\nSubgrouping means to place adjustments in further groupings if any partnership adjustment within any grouping is a negative adjustment. In general, \nan adjustment is subgrouped according to how the adjustment would be required to be taken into account separately under section 702(a) or any other \nprovision of the IRC or regulation applicable to the adjusted item. For purposes of creating subgroupings, if any adjustment could be subject to any \npreference, limitation, or restrictions under the IRC (or not allowed in whole or in part against ordinary income) if taken into account by any person, the \nadjustment is placed in a separate subgrouping from all other adjustments within the grouping. For partnerships under examination (and prior to any \nrequested and approved modifications), the subgrouping of each proposed partnership adjustment is shown on Form 14792 received by the partnership.\n", "6\nTax attribute is anything that can affect the amount or timing of a partnership-related item that can affect the amount of tax due in any taxable year. \nExamples of tax attributes include, but are not limited to, basis and holding period, as well as the character of items of income, gain, loss, deduction, or \ncredit and carryovers and carrybacks of such items. Regarding a relevant partner’s tax attributes affected by reason of taking into account its distributive \nshare of all partnership adjustments in the partner’s first affected year, see Form 8982 and instructions for more information.\nTax-Exempt Partner (for purposes of the modification of a partnership’s imputed underpayment under section 6225(c)(3)) is defined as a relevant \npartner which is a tax-exempt entity under section 168(h)(2)(A), (C), and (D). If this modification is requested by the partnership, Form 8983 is a required \nrelated form to Form 8980. Therefore, the tax-exempt partner must complete and sign Form 8983 and provide it to the PR, unless the partner is a foreign \npartner exempt from tax under a provision other than section 501(a). The PR must submit Form 8983 (as a related form) when Form 8980 is submitted. \nSee Form 8980, Item E, Part II and the associated specific line instructions, along with Form 8983 and instructions.\nSpecific Instructions\nAll form fields appearing with a red outline on the fillable PDF form are mandatory fields. If these fields are not properly completed, the form \nmay not be accepted for further processing. Complete all appropriate lines and the signature block information (Partnership Representative/\nDesignated Individual information and signature).\nName fields: Do not enter double blank spaces or punctuation.\nTIN (Taxpayer Identification Number) fields: \n• \nFor TIN fields which can be either an Employer Identification Number (EIN) or Social Security Number (SSN), be sure to enter a dash \nwhen entering an EIN (Example: XX-XXXXXXX), and two dashes when entering an SSN (Example: XXX_XX-XXXX). \n• \nFor fields that stipulate an EIN or SSN, you do not need to enter the dashes, as the fillable form will appropriately format the number and \nautomatically include the dash/dashes.\nU. S. Zip Code fields: U.S. Zip Code fields should be entered as either 5 or 9 numeric digits, no dashes. The fillable form will automatically include a \ndash if 9 numeric digits are entered.\nDate fields: Use the drop-down calendar on the field to select the date when available. All dates must be in the following format: MM/DD/YYYY\nAudit control number. Enter the 10-digit audit control number for the partnership requesting modification. This number is located on the notice of \nproposed partnership adjustment (NOPPA) received by the partnership and PR, which includes Letter 5892/5892-A and Form 14792. If Form 8980 is \nbeing attached to an AAR, leave blank.\nPartnership Information\nLine 1 – Name. Enter the full name of the source partnership.\nLine 2 – Taxpayer ID Number (TIN). Enter the partnership’s Taxpayer Identification Number without dashes.\nLine 3 – Tax Year Ended. Using the drop-down calendar, select the date that is the last day of the partnership’s tax year for the reviewed year. The date \nmust be entered in the following format: MM/DD/YYYY. For example, a partnership requesting modification for a reviewed year that is calendar year \n2019 would select or enter: 12/31/2019.\nLine 4 – Type of address. Check the appropriate box to indicate whether the partnership’s address is either a domestic (U.S.) address or foreign \naddress. Once the appropriate box is checked, the relevant address fields will be visible for completion.\nLines 5 – Address. After checking the appropriate type of address on Line 4, complete Lines 5. \n• \nFor a domestic address, complete Lines 5a through 5d with the full address of the partnership. Be sure to use the drop-down menu choice \nfor Line 5c (State). All fields are required. \n• \nFor a foreign address, complete Lines 5a through 5e with the full foreign address. Be sure to use the drop-down menu choice for Line 5d \n(Country code). All fields are required. \nPartnership Representative (PR) Information\nLine 1 – Type of partnership representative. Check the appropriate box to indicate whether the partnership representative is an entity or individual. \nOnce the appropriate box is checked, the relevant fields will be visible for completion.\nLine 2 and 3 – Name and Taxpayer ID Number (TIN) of PR. If the partnership representative is an individual, enter the full name of the individual’s \nfull name and TIN. If the partnership representative is an entity, enter the name of the entity and its TIN, and complete the numbered lines under the \n“Designated Individual (DI) Information (if PR is an Entity)-.” Section.\nLines 4a through 4d – Street Address, City or town, State, and ZIP code. Include the full address of the partnership representative\nDesignated Individual (DI) Information (if PR is an entity)\nThis section only needs to be completed if the partnership representative is an entity.\nLines 1 and Line 2 – Name and TIN of Designated Individual. If the partnership representative is an entity, enter the full name of the Designated \nIndividual on lines 1a through 1c. Enter the Designated Individual’s Taxpayer ID Number (TIN) on line 2.\nLines 3a through 3d – Street Address, City or town, State, and ZIP code. Include the full address of the Designated Individual.\nWhich Parts of Form 8980 Need to Be Completed\nFor all Form 8980 submissions (whether “Original”, “Corrected”, “Supplemental”, or “Supporting Documents”) complete Items A through D, the \napplicable Parts of Item E (depending on the modifications requested), and Item F. \n", "7\nItem A – Modification Submission Type\nCheck the appropriate box for the type of Form 8980 being submitted. This is a required field. One check box must be selected:\n• \nOriginal Form 8980 – Check this box if this is the first modification request being submitted for the source partnership for the tax year. Note: If \nan “Original Form 8980” was submitted, but rejected, the Form 8980 when resubmitted should still be marked “Original Form 8980”;\n• \nSupplemental Form 8980 which should be considered in addition to a previously submitted Form 8980 original request – Check this box if the \nmodification request being submitted is in addition to an “Original Form 8980” already submitted by the source partnership for the tax year\n• \nCorrected Form 8980 that should replace a Form 8980 previously submitted – Check this box if the modification request (Original and any \nSupplementals) are being corrected by the source partnership for the tax year. Caution: A “Corrected Form 8980” can only be submitted if an \n“Original Form 898” has been submitted and its status is “Accepted”. A “Corrected Form 8980” replaces all prior Form 8980s submitted for the \nsource partnership for the tax year. Therefore, a “Corrected Form 8980” must be submitted in entirety and be all-inclusive. \n• \nSupporting documents only are being submitted to substantiate a previously submitted Form 8980 modification request – Check this \nbox if documents are being submitted which support an Original, Supplemental, or Corrected Form 8980 already submitted by the source \npartnership for the tax year.\n• \nA Form 8980 attached to the filing of an Administrative Adjustment Request (AAR). (Be sure to attach Form 8980 to the AAR when filed).\nItem B – Modification(s) Requested\nCheck the box corresponding to the types of modifications being requested. This is a required section, therefore at least one check box must be \nselected. Check all boxes that apply. When a box is checked in this section, it enables the related Part (Part I through IX) of Item E to be \nunlocked for completion. Therefore, failure to check a box in this section for a particular type of modification will prevent the Item E part of \nthe form from being completed properly. \nNote: For an AAR with modifications, the following types of modification are not permitted to be applied: Partner modification amended returns; \nPartner alternative procedure, and closing agreements. For further information regarding each type of modification, see the instructions for Item E – \nModifications Requested.\nItem C – Source Partnership Structure, Ownership, and Allocations of Adjustments Relevant to \nModification\nThis is a required section of the form that must be completed in all cases (whether “Original”, “Corrected”, “Supplemental”, or “Supporting \nDocuments” Form 8980). Therefore, if a “Corrected”, “Supplemental”, “Supporting Documents” Form 8980 is being submitted, it is suggested that \nyou start with a copy of the previously submitted Form 8980 to use as a starting point, and revise accordingly. This will lessen the amount of data entry \nneeded on the Item C, Structure section. If no revisions or additions are needed to the Item C, Structure section for the ”Corrected”, “Supplemental”, \nor “Supporting Documents” Form 8980, then you can use the previously submitted Form 8980, Item C Structure section, as is, for the “Corrected”, \n“Supplemental”, or “Supporting Documents” Form 8980. \nUse Item C to report the structure of the source partnership and the partners’ allocation of all proposed partnership adjustments relevant to the \nrequested modifications. Be sure to review the “Basic Examples” and the “Comprehensive Example” and “Solution to Comprehensive Example” within \nthe Item C Specific Instructions. The “Show Example” button at the Top of Form 8980, Item C, also shows the solution to the Comprehensive Example.\nItem C – General Instructions\nBefore Completing Item C: Click on the “Show Example” button on Form 8980, Item C, to see an example of how Item C is completed). The example \nfacts are included below in these instructions.\nSource Partnership Structure: Tiers, Partners, and Ownership: This is a required section of the form. The applicable partners of the source \npartnership must be properly identified, along with their respective profit, loss and capital ownership percentages in the source partnership. For any \nrelevant partner that is not a direct partner, it is important that all partners within the chain of ownership leading to a relevant partner be properly \nidentified. If the partners are not properly identified (including correct name and TIN), it may cause Form 8980 to fail IRS TIN validation, causing the form \nto reject. \nAllocation of Adjustments Relevant to Modification: This is a required section of the form. For each partnership adjustment relevant to the \nmodification request, a table should be completed. For each table (representing one partnership adjustment), the following fields are required:\n• \nIU type (in table header);\n• \nGrouping (in table header);\n• \nSubgrouping (in table header);\n• \nAdjustment description (in column 9 header field);\n• \nTotal adjustment amount (in the field directly below the Adjustment description, and above Line 1)\n• \nTIN of Partner\n• \nRelevant Partner’s allocation (column 13)\nThe rest of the table should detail how the total adjustment amount is allocated to the partners and relevant partners. The allocations pertaining to the \nrelevant partners must be shown in column 13. The amounts that are listed in column 13 of each table should represent the allocations of all partnership \nadjustments from the source partnership which are relevant to the modifications requested. This information is necessary in order for the IRS to evaluate \nand approve the modifications requested in Item E. The failure to provide such information may result in the IRS’s denial, in whole or in part, of the \nsource partnership’s requested modifications. \nItem C – Specific Instructions\nSource Partnership Structure: Tiers, Partners, and Ownership. See the Example below in these instructions, and click on the “Show Example” \nbutton on Form 8980, Item C, to see an example of how Item C is completed. \nA. Total number of partners (direct and indirect) for the source partnership structure, ownership, and allocations of adjustments relevant to \nmodification. This is a required field. By entering the total number of partners, the form will populate with the necessary number of lines for \ncompletion of the structure table and the allocation of adjustments table(s). \nNote regarding the first line of the table: The first line of the table is reserved for the source partnership and therefore is not numbered. The fillable \nPDF will auto-populate the non-numbered source partnership line once the source partnership name and TIN are entered on Page 1, Partnership \nInformation, Line 1 and Line 2.\n \n", "8\nAfter the non-numbered line for the source partnership, the following partners must be listed in the Source Partnership Structure: Tiers, Partners, and \nOwnership table:\n• \nAll direct partners of the source partnership; and\n• \nAll relevant partners of the source partnership (if not already included due to the partner also being a direct partner); and\n• \nAny pass-through partner and disregarded entity in the chain of ownership between the relevant partners and the source partnership.\n(See “Definitions” earlier in these instructions for the terms used above in order to properly identify the partners in Item C).\nNote regarding partners that must be listed in the Item C structure table and allocations table(s): For Item C, not all of the partners in all tiers \nneed to be listed in the Source Partnership Structure table and Allocation of Adjustments Relevant to Modification table(s) – Only direct partners, \nrelevant partners (if not direct partners), and pass-through partners and disregarded entities in the chain of ownership between the relevant partners and \nthe source partnership need to be listed. See the “Comprehensive Example” further down in these instructions which illustrates this point.\nNote regarding the number of lines entered on Line A: If the number entered on Line A exceeds 999 partners, the form must be completed up \nthrough partner number 999. The structure information exceeding 999 partners should be included on schedules or statements attached to Form 8980. \n(The form will populate with “See attached” on row number 1,000).\nAs a reminder: See the Example below in these instructions, and click on the “Show Example” button on Form 8980, Item C, to see an example of how \nItem C is completed. \nFor all lines in the table after the first line for the source partnership (which will be populated automatically from page 1 information), use the \nfollowing instructions:\nColumn (1): Source partnership (Tier 1) Direct Partners. For each direct partner to be identified in columns 3 through 5, enter “1” to indicate that the \npartner is a direct partner in tier 1 of the partnership’s structure. For all partners identified that are not a direct partner, leave column 1 blank.\nColumn (2): Tier Number (if not a direct partner). For each indirect partner to be identified in columns 3 through 5, enter the tier number to indicate \nthe tier of the source partnership’s structure that the indirect partner relates. (As a reminder: See the Example below in these instructions, and click on \nthe “Show Example” button on Form 8980, Item C, to see an example of how Item C is completed).\nColumn (3): Partner Name & Type of Partner. First check the box indicating whether the partner is an entity or individual partner. Once the box is \nchecked to indicate the type of partner, the name fields will be visible for completion. This is a required checkbox. Once the type of partner checkbox is \nselected, then enter the complete name of the partner. This is a required field.\nColumn (4): TIN. Enter the Employer Identification Number (EIN) if an entity partner, or Social Security Number (SSN) if an individual partner for the \npartner identified in column 3. This is a required field. Be sure to enter the appropriate dashes in the correct placement of the number. (If an EIN: XX-\nXXXXXXX, or if an SSN: XXX-XX-XXXX). If the format of the TIN entered does not match the type of partner selected, the form may be rejected.\nCaution: The partner TINs (EIN or SSN) should be known based on TIN information from the Schedule K-1s issued to reviewed year partners. If the EIN \nor SSN is unknown, select “Unknown” from the drop-down box. If you select “Unknown” for a partner and the IRS has EIN or SSN information for the \npartner, the form may be rejected.\nColumn (5): Entity Type. This is a required field. Using the drop-down menu, select the type of entity for the partner identified in column 3 and 4. For \ndirect partners (Tier 1), this should be the type of entity indicated on the partner’s original reviewed year Schedule K-1 from the source partnership. \n(i.e., Individual, Corporation, S corporation, Estate, Trust, Partnership, Disregarded Entity, Exempt Organization, Individual Retirement Arrangement \n(IRA), or Foreign Government). For indirect partners, the entity type indicated should be consistent with the original Schedule K-1 issued to the indirect \npartner by the pass-through partner in the chain of ownership through which the indirect partner of the source partnership holds a direct interest.\nColumns (6), (7), and (8): % of Source Partnership – (6) Profit %, (7) Loss % and (8) Capital %. For column 6, 7 and 8, enter the partner’s \npercentage share of the source partnership’s profit, loss, and capital at the end of the partnership’s reviewed year, as determined under the partnership \nagreement. An entry is required in at least one column (column 6, 7, or 8), for each partner included in the structure.\n• \nFor direct partners: Such percentages entered in column 6, 7 and 8 should be consistent with the Schedule K-1’s issued to the partners for \nthe reviewed year, unless an examination adjustment affected such percentage. As a check, the total percentage for each column 6, 7 and 8 \nfor all direct partners should equal 100%. \n• \nFor indirect partners: The percentages entered on Line 6, 7 and 8 should be the percentage of profit, loss and capital ownership in the \nsource partnership (not the ownership percentages in the pass-through partner through which the partner holds its interest in the source \npartnership). \nThese fields allow up to four digits after the decimal. For example: 12.5555. If a percentage exceeds four decimal places, you may round. For example, \nfor a partner with a 12.55557% interest, enter: 12.5556. Do not enter a percentage sign since it is already hard-coded on the form. \nAllocation of Adjustments Relevant to Modification\nSee the “Basic Example” in this section as well as the Comprehensive Example and Solution for examples on how this portion of Item C must be \ncompleted. The “Show Example” button on Form 8980, Item C, also shows the Comprehensive Example Solution.\nNote for each proposed partnership adjustment included in Form 14792 (or AAR) that is relevant to modification, an allocation table must be \ncompleted in this section.\nTo insert additional adjustment tables, click on the “Add Adjustments” button and the table will populate with additional columns 9 through 13. \nFor each additional table added, the column headings 9-13 will automatically be labelled with “c”, “d”, etc. (for example, 9c, 10c, 11c, 12c, 13c). For \nexample, if there are three adjustments included on Form 14792 which are relevant to the requested modification(s), there must be three \nallocation tables completed (one for each adjustment). The allocation table for the first adjustment will have columns 9a through 13a. The \nallocation table for the second adjustment will have columns 9b through 13b. And the allocation table for the third adjustment will have \ncolumns 9c through 13c.\nThe following specific instructions apply for each adjustment table.\nCaution: Once you enter the number of relevant partners in the Item C, Structure table (Item C, Line A), the same number of relevant partner lines will \npopulate in the Item C, Allocation of Adjustment Relevant to Modification tables upon completion of the “Imputed Underpayment” drop-down field in the \nheader area (above columns 9a through 13a). Therefore, if you later revise the number of relevant partners entered on Item C, Line A on the fillable PDF, \nyou must click back in the “Imputed Underpayment” drop-down field in order to get the Allocation of Adjustments Relevant to Modification table(s) to \nrefresh with the appropriate number of lines for relevant partners. \n", "9\nTop Heading Area of Each Table (Above Columns (9) through (13)): For Each Adjustment Included in Form 14792 (or AAR) and relevant to \nmodification, an adjustment allocation table should be completed. Complete the heading area of the allocations table (Imputed Underpayment, \nGrouping, and Subgrouping) above columns 9a through 13a which includes the drop-down menu choices (and customized type-in choice) for imputed \nunderpayment type, and subgrouping. For each proposed partnership adjustment included in the source partnership’s Form 14792 (or included in the \nAAR) (both positive and negative adjustments) which is relevant to modification, you will complete an adjustment allocations table.\nFor each adjustment allocations table, complete the following required fields:\nImputed Underpayment: Choose from the drop-down menu the imputed underpayment type (either General or Specific 1), depending on how it was \nclassified per Form 14792 or determined in an AAR. There is also a customizable fill-in choice if the adjustment table being completed relates to an \nadjustment that was included in a specific IU other than Specific 1 in Form 14792. This is a required field. \nNote: Selection of the Imputed Underpayment type will activate the allocation table to populate with the number of lines for relevant partners \nbased on the number of relevant partners entered on Item C, Line A above the Structure table. Also, see “Caution” note above; and\nGrouping: Choose from the drop-down menu, the name of the grouping for the adjustment as indicated on Form 14792 or determined in an AAR \n(Reallocation, Residual, Creditable Expenditure, or Credit); This is a required field. and\nSubgrouping: Click on the first menu choice and type in the customized subgrouping for the adjustment as indicated on Form 14792. Abbreviate the \nsubgrouping description as necessary to fit in the custom field (up to 35 characters). This is a required field. \nColumn 9(a, b, c, etc.) – Source Partnership Adjustment Allocation to Direct Partners\nColumn 9(a, b, c, etc.) - Fillable field inside column heading: In the fillable area within the column 9a heading, type in the description of the \npartnership adjustment as stated on Form 14792 or as included in the AAR that is relevant to modification. You may abbreviate the adjustment \ndescription as necessary. This is a required field.\nColumn (9a, b, c, etc.) Source partnership line (Fillable field on the line for the source partnership (to the right of the pre-populated \nsource partnership TIN and underneath the adjustment description): Enter the total amount of partnership adjustment per Form 14792 \n(or per AAR) that relates to the adjustment description that was entered in the fillable field inside the column heading. This amount should be the \ntotal partnership adjustment as reported on Form 14792. Negative amounts should be typed in with a “-“ sign, and no commas. The form will \nautomatically format the number. For example, if the total partnership adjustment is (100,000), you would type in “-100000”, and the form will \nautomatically format it to “(100,000)”. This is a required field.\nBasic Example:\nA source partnership has two proposed partnership adjustment included on Form 14792:\nResidual Grouping:\nSubgrouping: Ordinary business income (loss), Sch K, Line 1\nGross receipts\t\n500,000\nLegal and professional fees\t\n(300,000)\t\n\t\n\t\n\t\n\t\nItem C, Allocation of Adjustments Relevant to Modification header areas of the adjustment allocations tables would be completed as follows, for each \nadjustment:\nPage 3 of 1\nAllocation of Adjustments Relevant to Modification\nImputed Underpayment: GENERAL\nGrouping: RESIDUAL\nSubgrouping: Ordinary bus inc(loss) Sch K Ln 1\nTIN of Partner \n(9a)\nSource \nPartnership \nAdjustment \nAllocation to Direct \nPartners:\nGross receipts\n(10a)\nCheck for \nSpecial \nAllocations\n(11a)\n Subsequent Tier's \nAllocations\n(12a)\nCheck for \nSpecial \nAllocations\n(13a)\nRelevant Partner's \nAllocations\n12-3456789\n 500,000 \n1.\n,PSXWHG\u00038QGHUSD\\PHQW\u001d\u0003 (1(5$/\nURXSLQJ\u001d 5(6,'8$/\n6XEJURXSLQJ\u001d 2UGLQDU\\\u0003EXV\u0003LQF\u000bORVV\f\u00036FK\u0003.\u0003/Q\u0003\u0014\n7,1\u0003RI\u00033DUWQHU\u0003\n\u000b\u001cE\f\n6RXUFH\u0003\n3DUWQHUVKLS\u0003\n$GMXVWPHQW\u0003\n$OORFDWLRQ\u0003WR\u0003'LUHFW\u0003\n3DUWQHUV\u001d\n/HJDO\u0003\t\u0003SURIHVVLRQDO\u0003\nIHHV\n\u000b\u0014\u0013E\f\n&KHFN\u0003IRU\u0003\n6SHFLDO\u0003\n$OORFDWLRQV\n\u000b\u0014\u0014E\f\n\u00036XEVHTXHQW\u00037LHU\nV\u0003\n$OORFDWLRQV\n\u000b\u0014\u0015E\f\n&KHFN\u0003IRU\u0003\n6SHFLDO\u0003\n$OORFDWLRQV\n\u000b\u0014\u0016E\f\n5HOHYDQW\u00033DUWQHU\nV\u0003\n$OORFDWLRQV\n\u0014\u0015\u0010\u0016\u0017\u0018\u0019\u001a\u001b\u001c\n\u000b\u0016\u0013\u0013\u000f\u0013\u0013\u0013\f\n\u0014\u0011\n1HJDWLYH\u0003DPRXQWV\u0003VKRXOG\u0003EH\u0003W\\SHG\u0003LQ\u0003ZLWK\u0003D\u0003³\u0010³\u0003VLJQ\u000f\u0003DQG\u0003\nQR\u0003FRPPDV\u0011\u00037KH\u0003IRUP\u0003ZLOO\u0003DXWRPDWLFDOO\\\u0003IRUPDW\u0003WKH\u0003\nQXPEHU\u0011\u0003,Q\u0003WKLV\u0003H[DPSOH\u000f\u0003\\RX\u0003ZRXOG\u0003W\\SH\u0003LQ\u0003³\u0010\u0016\u0013\u0013\u0013\u0013\u0013´\u000f\u0003\nDQG\u0003WKH\u0003IRUP\u0003ZLOO\u0003DXWRPDWLFDOO\\\u0003IRUPDW\u0003LW\u0003WR\u0003³\u000b\u0016\u0013\u0013\u000f\u0013\u0013\u0013\f´\u0011\n", "10\nColumn 9(a, b, c, etc.) – All lines After the line for the source partnership (beginning with Line 1).\nFor each direct partner in the source partnership, beginning on Line 1, enter the:\n• \nTIN of the direct partner in the “TIN of Partner” column (before/ to the left of column 9). The partner’s TIN (EIN or SSN) must be \nconsistent with the TIN listed for the partner in the partnership structure table section of Item C. \n• \nDirect partner’s distributive share allocation of the total partnership adjustment which was entered on the source partnership line. The partner’s \ndistributive share of partnership adjustment should be consistent with the allocation percentage information entered in columns 6, 7 and 8 \nof the Source Partnership Structure table, regarding profit, loss and capital percentages in the source partnership unless there is a special \nallocation. If the distributive share amount entered in column 9 is a special allocation, check the box in column 10. As a check, the total of all \namounts entered in column 9 after line 1 should equal the amount entered on line 1. If the direct partner is also a relevant partner (included in \none of the requested modifications on Form 8980, Item E), then also enter the partner’s allocation in column 13.\nFor all indirect partners, leave column 9 blank.\nInstead, complete column 11 for the indirect partner’s allocation. If the indirect partner is a relevant partner (included in one of the requested \nmodifications on Form 8980, Item E), then also enter the partner’s allocation in column 13. \nColumn (10): Check for Special Allocations. If the amount entered in column 9 for the direct partner’s distributive share amount is a special allocation \n(not based on the allocation percentage information entered in columns 6 through 8), check the box in column 10.\nColumn (11): Subsequent Tier’s Allocations. \nFor all direct partners in the source partnership, leave column 11 blank. \nFor each indirect partner, enter in column 11, the partner’s distributive share of the source partnership’s adjustment identified on Line 1. The \ndistributive share of partnership adjustment should be consistent with the allocation percentage information entered in columns 6, 7 and 8 regarding \nprofit, loss and capital percentages in the source partnership unless there is a special allocation. If the distributive share amount entered in column \n11 is a special allocation, check the box in column 12.\nColumn (12): Check for Special Allocations. If the amount entered in column 11 for the indirect partner’s distributive share amount is a special \nallocation (not based on the allocation percentage information entered in columns 6 through 8), check the box in column 12.\nColumn (13): Relevant Partner’s Allocations. \nFor all direct partners which are also relevant partners (included in one of the requested modifications on Form 8980, Item E), enter in column 13 \nthe amount from column 9. \nFor all indirect partners which are also relevant partners (included in one of the requested modifications on Form 8980, Item E), enter in column \n13 the amount from column 11.\nContinuing with the Basic Example:\nA source partnership (EIN: 12-3456789) has two proposed partnership adjustment included on Form 14792:\nResidual Grouping:\nSubgrouping: Ordinary business income (loss), Sch K, Line 1\nGross receipts\t\n500,000\nLegal and professional fees\t\n(300,000)\t\n\t\n\t\n\t\n\t\nThe source partnership has two partners, each owning 50% of the profit, loss, and capital: John Maple (an individual); and Trees Partners, LP (a \npartnership). Trees Partners, LP has two individual partners, each owning 50% of the profit, loss, and capital: Laurel Balsam; and Hazel Birch. The \nfollowing is a summary of the ownership percentages in the source partnership:\nPartner\nPartner TIN\nDirect Partner Ownership %\nPartner Ownership % in Source Partnership\nJohn Maple\n111-11-1111\n50%\n50%\nTrees Partners, LP\n22-2222222\n50%\n50%\nLaurel Balsam\n333-33-3333\n25%\nHazel Birch\n444-44-4444\n25%\n100%\nAll income, expenses, losses, deductions, and credits are allocated pro-rata (no special allocations). The source partnership will request modification for \npartner, Hazel Birch, based on a modification amended return filed. As a result, Hazel Birch is a relevant partner. The source partnership would complete \nthe Item C, Allocation of Adjustments Relevant to Modification tables for the two partnership adjustments, as follows:\n", "11\nAdjustment 1:\nPage 3 of 14\nCatalog Number 37818U\nwww.irs.gov\nForm 8980 (Rev. 10-2020)\nAllocation of Adjustments Relevant to Modification\nImputed Underpayment: GENERAL\nGrouping: RESIDUAL\nSubgrouping: Ordinary bus inc(loss) Sch K Ln 1\nTIN of Partner \n(9a)\nSource \nPartnership \nAdjustment \nAllocation to Direct \nPartners:\nGross receipts\n(10a)\nCheck for \nSpecial \nAllocations\n(11a)\n Subsequent Tier's \nAllocations\n(12a)\nCheck for \nSpecial \nAllocations\n(13a)\nRelevant Partner's \nAllocations\n12-3456789\n 500,000 \n1.\n111-11-1111\n 250,000 \n2.\n22-2222222\n 250,000 \n3.\n333-33-3333\n 125,000\n4.\n444-44-4444\n 125,000\n 125,000\n 500,000 \n 125,000\nAdjustment 2:\nD \nR \nA \nF \nT \n \nC \nO \nP \nY\nN \nO \nT \n \nF \nO \nR \n \nR \nE \nL \nE \nA \nS \nE\nPage 4 of 15\nCatalog Number 37818U\nwww.irs.gov\nForm 8980 (Rev. 10-2020)\nImputed Underpayment: GENERAL\nGrouping: RESIDUAL\nSubgrouping: Ordinary bus inc(loss) Sch K Ln 1\nTIN of Partner \n(9b)\nSource \nPartnership \nAdjustment \nAllocation to Direct \nPartners:\nLegal & professional \nfees\n(10b)\nCheck for \nSpecial \nAllocations\n(11b)\n Subsequent Tier's \nAllocations\n(12b)\nCheck for \nSpecial \nAllocations\n(13b)\nRelevant Partner's \nAllocations\n12-3456789\n(300,000)\n1.\n111-11-1111\n(150,000)\n2.\n22-2222222\n(150,000)\n3.\n333-33-3333\n(75,000)\n4.\n444-44-4444\n(75,000)\n(75,000)\n(300,000)\n(75,000)\nItem C Comprehensive Example \nThe following is a comprehensive example of how Item C (Structure table and Allocations tables) should be completed. The solution is shown here \nafter the facts of the example; however, you may also click on the “Show Example” button on Form 8980, Item C to see the comprehensive example’s \nsolution. \nABCDEFG, LP, a source partnership, has 7 direct partners, and 13 indirect partners, comprised of 4 Tiers, structured as follows for the Reviewed Year \n2020:\n1.\t\nA Company, Inc. (a C corporation): 10% [Direct: Tier 1]\n2.\t\nB. Brown: 10% [Direct: Tier 1]\n3.\t\nCC 2012 Irrevocable Trust (Trust): 5% [Direct: Tier 1]\na.\t\nC. C. Brown (100% Beneficiary) [Tier 2]\n4.\t\nD Corporation, Inc. (an S corporation): 5% [Direct: Tier 1]\na.\t\nD. D. Blue (100% Shareholder) [Tier 2]\n5.\t\nEnergy Partners, LP (a Partnership): 60% [Direct: Tier 1]\na.\t\nEnergy Family Trust: 20% [Tier 2]\nb.\t\nE. E. Green: 20% [Tier 2]\nc.\t\nE. F. Green: 20% [Tier 2]\nd.\t\nEEE Opportunity Fund (a Partnership): 20% [Tier 2]\ni.\t\nE. G. Green: 20% Foreign Non-resident alien [Tier 3]\nii.\t\nE. H. Green: 20% [Tier 3]\niii.\t\nEEE Asset Management, LP (a Partnership): 60% [Tier 3]\n1.\t\nE. I. Green: 50% [Tier 4]\n2.\t\nE. J. Green: 50% [Tier 4]\ne.\t\nThe Triple E Foundation (Exempt Organization): 20% [Tier 2]\n", "12\n6.\t\nFriends Management, LLC (a Disregarded Entity): 5% [Direct: Tier 1]\na.\t\nFriends Infrastructure Corporation (a C corporation): 100% Sole Member [Tier 2]\n7.\t\nGHIJK Pension Fund (an Exempt Organization): 5% [Direct: Tier 1]\nThe partnership examination of ABCDEFG, LP resulted in the following audit adjustments:\nOrdinary business income\n$1,000,000\nLong-term capital gain\n500,000\nPortfolio deductions (increase)\n(1,000)\nThe following is a summary of the Form 14792 included with the NOPPA issued to the partnership:\nGeneral Imputed Underpayment\n1.\nReallocation Grouping\nSubgroup\nPositive \nAdjustment\nNegative \nAdjustment\nA.\ni.\nSubtotal for subgroup\n2.\nSum of all net positive Reallocation Grouping adjustments (only include net positive \nadjustments in the total. See Line 3 for net negative adjustments)\n3.\nSum of all net negative Reallocation Grouping Adjustments (only include net \nnegative adjustments in the total. See Line 2 for net positive adjustments)\n4.\nResidual Grouping\nA.\nOrdinary business income (loss), Sch K, Line 1\ni.\nOrdinary business income\n 1,000,000 \nSubtotal for subgroup\n 1,000,000 \nB.\nNet long-term capital gain (loss), Sch K, Line 9a\ni.\nLong-term capital gain\n 500,000\nSubtotal for subgroup\n 500,000\nC.\nOther deductions, Sch K, Line 13d (Code L)\ni.\nPortfolio deductions\n(1,000)\nSubtotal for subgroup\n(1,000)\n5.\nSum of all net positive Residual Grouping adjustments (only include net positive \nadjustments in the total. See Line 6 for net negative adjustments)\n6.\nSum of all net negative Residual Grouping adjustments (only include net negative \nadjustments in the total. See Line 5 for net positive adjustments)\n(1,000)\n7.\nSum of all net positive adjustments from Reallocation and Residual Groupings \n(add Lines 2 and 5). Total netted partnership adjustments\n 1,500,000 \n8.\nSum of all net negative adjustments from Reallocation and Residual Groupings \n(add Lines 3 and 6). This amount is ignored for calculating the imputed \nunderpayment\n(1,000)\n9.\nHighest effective tax rate for the tax year ended\n%\n37\n10. Imputed Underpayment before Creditable Expenditures and Credit Groupings \n(multiply Line 7 by Line 9)\n 555,000\n11. Creditable Expenditures Grouping (decreases to creditable expenditures are positive \nadjustments and increases are negative adjustments)\nA.\ni.\nSubtotal for subgroup\n12. Sum of all net positive adjustments in the Creditable Expenditure Grouping (only \ninclude net positive adjustments in the total. See Line 13 for net negative adjustments)\n13. Sum of all net negative adjustments in the Creditable Expenditure Grouping (only \ninclude net negative adjustments in the total. See Line 12 for net positive adjustments)\n14. Credit Grouping (decreases to credits are positive adjustments and increases are \nnegative adjustments)\nA.\ni.\nSubtotal for subgroup\n15. Sum of all net positive adjustments in the Credit Grouping (only include net positive \nadjustments in the total. See Line 16 for net negative adjustments)\n16. Sum of all net negative adjustments in the Credit Grouping (only include net \nnegative adjustments in the total. See Line 15 for net positive adjustments)\n17. Imputed Underpayment (add Lines 10, 12 and 15) \n 555,000\n", "13\nThe partnership plans to request the following modifications to the imputed underpayment:\n• \nPartner Modification Amended Returns filed inclusive of all properly allocable adjustments:\no\t\nB. Brown\no\t\nEEE Asset Management, LP\n• \nTax-Exempt Partners:\no\t\nGHIJK Pension Fund\no\t\nThe Triple E Foundation\n• \nTax Rate Reduction:\no\t\nE. E. Green – Capital Gain is taxed at 20% maximum rate\no\t\nFriends Infrastructure Corp – All income taxed at 21% highest corporate rate.\n• \nPartner Closing Agreement:\no\t\nA Company, Inc. enters into a closing agreement inclusive of all allocable adjustments.\nD \nR \nA \nF \nT \n \nC \nO \nP \nY\nN \nO \nT \n \nF \nO \nR \n \nR \nE \nL \nE \nA \nS \nE\nPage 3 of 19\nCatalog Number 37818U\nwww.irs.gov\nForm 8980 (Rev. 10-2020)\nA. Total number of partners (direct and indirect) for the source partnership structure, ownership, and allocations of adjustments relevant to modification\n12\nSource Partnership Structure: Tiers, Partners, and Ownership\n(1) \n Source Partnership \n(Tier 1) \nDirect Partners\n(2) \nTier Number \n(if not a direct \npartner)\n(3) \nPartner Name \n \n(4) \nTIN\n(5) \nEntity Type\n% of Source Partnership\n(6) \nProfit %\n(7) \nLoss %\n(8) \nCapital %\nType of partner\nEntity\nIndividual\nSource Partnership\n12-3456789\nSOURCE PARTNERSHIP\n1.\n1\nType of partner\nEntity\nIndividual\nA Company, Inc.\nXX-XXXXXXX\nCORPORATION\n10%\n10%\n10%\n2.\n1\nType of partner\nEntity\nIndividual\nFirst name\nB\nMiddle name\nB\nLast name\nBrown\nXXX-XX-XXXX\nINDIVIDUAL\n10%\n10%\n10%\n3.\n1\nType of partner\nEntity\nIndividual\nCC 2012 Irrevocable Trust\nXX-XXXXXXX\nTRUST\n5%\n5%\n5%\n4.\n1\nType of partner\nEntity\nIndividual\nD Corporation, Inc.\nXX-XXXXXXX\nS CORPORATION\n5%\n5%\n5%\n5.\n1\nType of partner\nEntity\nIndividual\nEnergy Partners, LP\nXX-XXXXXXX\nPARTNERSHIP\n60%\n60%\n60%\n6.\n2\nType of partner\nEntity\nIndividual\nFirst name\nE\nMiddle name\nE\nLast name\nGreen\nXXX-XX-XXXX\nINDIVIDUAL\n12%\n12%\n12%\n7.\n2\nType of partner\nEntity\nIndividual\nEEE Opportunity Fund\nXX-XXXXXXX\nPARTNERSHIP\n12%\n12%\n12%\n8.\n3\nType of partner\nEntity\nIndividual\nEEE Asset Management, LP\nXX-XXXXXXX\nPARTNERSHIP\n7.2%\n7.2%\n7.2%\n9.\n2\nType of partner\nEntity\nIndividual\nThe Triple E Foundation\nXX-XXXXXXX\nEXEMPT ORGANIZATION\n12%\n12%\n12%\n10.\n1\nType of partner\nEntity\nIndividual\nFriends Management LLC\nUNKNOWN\nDISREGARDED ENTITY\n5%\n5%\n5%\n11.\n2\nType of partner\nEntity\nIndividual\nFriends Infrastructure Corp\nXX-XXXXXXX\nCORPORATION\n5%\n5%\n5%\n12.\n1\nType of partner\nEntity\nIndividual\nGHIJK Pension Fund\nXX-XXXXXXX\nEXEMPT ORGANIZATION\n5%\n5%\n5%\n", "14\nD \nR \nA \nF \nT \n \nC \nO \nP \nY\nN \nO \nT \n \nF \nO \nR \n \nR \nE \nL \nE \nA \nS \nE\nPage 4 of 19\nCatalog Number 37818U\nwww.irs.gov\nForm 8980 (Rev. 10-2020)\nAllocation of Adjustments Relevant to Modification\nImputed Underpayment: General\nGrouping: Residual\nSubgrouping: Ordinary\nTIN of Partner \n(9a)\nSource \nPartnership \nAdjustment \nAllocation to Direct \nPartners:\nOrdinary Income \n(loss)\n(10a)\nCheck for \nSpecial \nAllocations\n(11a)\n Subsequent Tier's \nAllocations\n(12a)\nCheck for \nSpecial \nAllocations\n(13a)\nRelevant Partner's \nAllocations\n12-345678\n1,000,000\n1.\nXX-XXXXXXX\n100,000\n100,000\n2.\nXXX-XX-XXXX\n100,000\n100,000\n3.\nXX-XXXXXXX\n50,000\n4.\nXX-XXXXXXX\n50,000\n5.\nXX-XXXXXXX\n600,000\n6.\nXXX-XX-XXXX\n120,000\n120,000\n7.\nXX-XXXXXXX\n120,000\n8.\nXX-XXXXXXX\n72,000\n72,000\n9.\nXX-XXXXXXX\n120,000\n120,000\n10.\nUNKNOWN\n50,000\n11.\nXX-XXXXXXX\n50,000\n50,000\n12.\nXX-XXXXXXX\n50,000\n50,000\nD \nR \nA \nF \nT \n \nC \nO \nP \nY\nN \nO \nT \n \nF \nO \nR \n \nR \nE \nL \nE \nA \nS \nE\nPage 5 of 19\nCatalog Number 37818U\nwww.irs.gov\nForm 8980 (Rev. 10-2020)\nImputed Underpayment: General\nGrouping: Residual\nSubgrouping: LTCG\nTIN of Partner \n(9b)\nSource \nPartnership \nAdjustment \nAllocation to Direct \nPartners:\nNet Long-term \nCapital Gain (lo\n(10b)\nCheck for \nSpecial \nAllocations\n(11b)\n Subsequent Tier's \nAllocations\n(12b)\nCheck for \nSpecial \nAllocations\n(13b)\nRelevant Partner's \nAllocations\n12-345678\n500,000\n1.\nXX-XXXXXXX\n2.\nXXX-XX-XXXX\n3.\nXX-XXXXXXX\n4.\nXX-XXXXXXX\n250,000\n5.\nXX-XXXXXXX\n250,000\n6.\nXXX-XX-XXXX\n50,000\n50,000\n7.\nXX-XXXXXXX\n50,000\n8.\nXX-XXXXXXX\n30,000\n30,000\n9.\nXX-XXXXXXX\n50,000\n50,000\n10.\nUNKNOWN\n11.\nXX-XXXXXXX\n12.\nXX-XXXXXXX\n", "15\nImputed Underpayment: General\nGrouping: Residual\nSubgrouping: Portfolio Deductions\nTIN of Partner \n(9c)\nSource \nPartnership \nAdjustment \nAllocation to Direct \nPartners:\nPortfolio Deductions\n(10c)\nCheck for \nSpecial \nAllocations\n(11c)\n Subsequent Tier's \nAllocations\n(12c)\nCheck for \nSpecial \nAllocations\n(13c)\nRelevant Partner's \nAllocations\n12-345678\n-1,000\n1.\nXX-XXXXXXX\n-100\n-100\n2.\nXXX-XX-XXXX\n-100\n-100\n3.\nXX-XXXXXXX\n-50\n4.\nXX-XXXXXXX\n-50\n5.\nXX-XXXXXXX\n-600\n6.\nXXX-XX-XXXX\n-120\n-120\n7.\nXX-XXXXXXX\n-120\n8.\nXX-XXXXXXX\n-72\n-72\n9.\nXX-XXXXXXX\n-120\n-120\n10.\nUNKNOWN\n-50\n11.\nXX-XXXXXXX\n-50\n-50\n12.\nXX-XXXXXXX\n-50\n-50\nYou may also click on the “Show Example” button at top of Item C of Form 8980 to see this solution to the comprehensive example. \nReminder: Note regarding partners that must be listed in the Item C structure table and allocations table(s): For Item C, not all of the partners \nin all tiers need to be listed in the Source Partnership Structure table and Allocation of Adjustments Relevant to Modification table(s) – only all direct \npartners, relevant partners and pass-through partners and disregarded entities in the chain of ownership between the relevant partners and the source \npartnership need to be listed. In the comprehensive example within the “Show Example” button, even though the source partnership has 20 direct and \nindirect partners (7 direct, 13 indirect), only 12 of the 20 partners meet the criteria to be listed.\nItem D – Request for Modification Pre-Approval Involving Modifications Relating to Partners of \na Pass-Through Partner\nUse Item D to request the pre-approval of modifications relating to partners of a pass-through partner (for which the pass-through partner wants to take \ninto account such approved modifications relating to its partners when the pass-through partner either files a modification amended return or chooses \nthe alternative procedure. A pass-through partner of a source partnership that wants to apply modifications for purposes of its payment calculation \npursuant to applicable Regulations, must receive pre-approval through the source partnership’s modification request, in order to take such modifications \ninto account. The source partnership (not the pass-through partner), should use Item D to request the pre-approval of modifications relating to partners \nof a pass-through partner. Enter in Item D, the following information:\n• \nExplanation of the requested pre-approval including the pass-through partner’s name and TIN, the pass-through partner’s partners \n(names and TINs), and the types of modifications requested. (If additional space is needed, indicate “see attached” and attach a separate \nstatement(s). Any additional statements or schedules detailing the request should be uploaded as an attachment to Form 8980.\n• \nIn addition, complete:\no\t\nThe appropriate parts of Item E (Modification types requested) which should include the partners of the pass-through partner which are \nrelevant to the pre-approval request. For each partner of the pass-through partner included in the request, be sure to include all required \ninformation pertaining to the type of modification requested for each partner, by following the instructions for each type of modification \n(Item E, Parts I through X; and\n• \nItem C (Source Partnership Structure, Ownership, and Allocations of Adjustments Relevant to Modification). This should be completed \nincluding all relevant partners (the pass-through partner and its partners for which the pre-approval is being requested) and allocations of \nadjustments relevant to the modifications (inclusive of the pass-through partner and its partners for which pre-approval is being requested).\nOnce this information is received and reviewed by the IRS, we will contact the PR regarding the pre-approval. The pass-through partner may not apply \nany such modifications to its payment calculation in an amended return filing or alternative procedure selection until the IRS notifies the PR regarding the \npre-approval request.\nItem E – Modifications Requested\nPart I – Amended Returns of Partners Under IRC Section 6225(c)(2)(A) & Alternative Procedure of Partners Under \nIRC Section 6225(c)(2)(B) \nGeneral Instructions\nPartner Modification Amended Returns\nUnder section 6225(c)(2), an imputed underpayment will be determined without regard to the portion of the adjustments taken into account through \npartner modification amended returns. Use this part of Form 8980 to request modifications to the partnership’s imputed underpayment(s) for any \nmodification amended returns filed by a direct or indirect partner of the source partnership requesting modification. Each relevant partner must complete \n", "16\nand sign a Form 8982, Affidavit for Partner Modification Amended Return Under IRC §6225(c) (2)(A) or Partner Alternative Procedure Under IRC \n§6225(c)(2)(B). A Form 8982 for each partner listed in this part must be submitted as a related form to Form 8980 when Form 8980 is submitted. If the \nIRS approves a modification for a partner modification amended return under this section, the partnership may not request additional modifications with \nrespect to that partner or with respect to the partnership adjustment allocated to such partner.\nCaution: Partner amended return modification and partner alternative procedure modification are not permitted for an AAR.\nFiling Instructions for Modification Amended Returns. Special filing instructions apply to all partner modification amended returns filed for the first \naffected year and all modification years. See “Filing Instructions for Modification Amended Returns” located in the instructions to Form 8982. In \naddition to filing the modification amended returns according to such instructions, the partner must also complete and sign Form 8982 and provide it to \nthe PR.\nPartner Statute of Limitations. For purposes of modification amended return filed under section 6225(c)(2), the partner’s statute of limitations under \nsection 6501 or section 6511 are not required to be open for any modification amended returns filed in the partner’s first affected year and any other \nmodification years.\nForm 8982 Must Be Attached for Each Partner. For each partner listed in Part I, a Form 8982, must be a completed and signed by the partner, \nprovided to the PR, and attached to Form 8980 when Form 8980 is submitted by the PR. Form 8982 is a requirement, among others, in order for the \nmodification to be approved.\nAll Properly Allocable Adjustments Must Be Reported by the Partner. The modification amended returns must take into account all adjustments \nproperly allocable to such partners (positive and negative adjustments) for the partner’s first affect year, and for all modification years with respect to any \nadjustments to the partner’s tax attribute affected by reason of taking the partnership adjustments into account in the first affected year. The reporting of \nall adjustments properly allocable to a partner in modification amended return(s) is a requirement in order for the modification to be approved. In addition \nto the other requirements under section 6225(c)(2)(A), if all proper adjustments are not included in the partner modification amended return(s), the \nmodification request cannot be approved.\nBinding Effect on Relevant Partner Tax Attributes. Any adjustments to tax attributes of any relevant partner which are affected by modification for \namended returns are binding on the relevant partner with respect to the first affected year and all modification years. A failure to adjust any tax attribute \nis a failure to treat a partnership-related item in a manner which is consistent with the treatment of such item on the partnership return within the meaning \nof section 6222. The provisions of section 6222(c) and applicable Regulations (regarding notification of inconsistent treatment) do not apply with respect \nto such tax attributes.\nFull Payment Required. Payment of any tax due, penalties, additions to tax, additional amounts, and interest due as a result of taking into account all \npartnership adjustments in the first affected year and all modification years must be made at the time of filing the partner modification amended return(s). \nThe payment of all amounts due by the partner is a requirement in order for the modification request to be approved. See the instructions in Form 8982 \nfor how to pay and properly identify payments.\nReallocation Adjustments. In the case of adjustments which reallocate a distributive share of any item from one partner to another, if one partner \nchooses to file a modification amended return, then all partners involved in the reallocation must either file an amended return, select the alternative \nprocedure, or enter a closing agreement, in order for the modification to be approved.\nFurther Partner Amended Returns Restricted. A partner that files a modification amended return which has been accepted by the IRS generally may \nnot file a subsequent amended return for the same tax year and with respect to the same partnership adjustments in order to change the treatment of \nthe partnership adjustments that were previously taken into account with the modification amended return already filed. Exceptions to the general rule, \ninclude the following situations:\n• \nA subsequent modification amended return filed during the modification submission period in order to correct the modification amended return \nalready filed;\n• \nA subsequent amended return filed based on a final court determination that reduces or eliminates an imputed underpayment, or protective \nclaim filed in anticipation of a final court decision; and\n• \nA subsequent amended return filed in order to take into account adjustments from another source partnership examination.\nSubsequent modification amended return filed within the unexpired modification submission period\nSubsequent modification amended return filed within the unexpired modification submission period. If the partnership’s modification submission \n. If the partnership’s modification submission \nperiod has not expired, and a partner needs to file another modification amended return in order to correct the first modification amended return filed and \nperiod has not expired, and a partner needs to file another modification amended return in order to correct the first modification amended return filed and \naccepted by the IRS, the partner should file the subsequent modification amended return in the same manner as the first modification amended return \naccepted by the IRS, the partner should file the subsequent modification amended return in the same manner as the first modification amended return \nfiled by following the instructions to Form 8982. The PR should submit another Form 8980 and check the “Corrected Form 8980” box on Form 8980, \nfiled by following the instructions to Form 8982. The PR should submit another Form 8980 and check the “Corrected Form 8980” box on Form 8980, \nItem A. In addition, another Form 8982 must be completed by the partner, and must be attached to Form 8980 by the PR. For filing instructions for a \nItem A. In addition, another Form 8982 must be completed by the partner, and must be attached to Form 8980 by the PR. For filing instructions for a \nsubsequent amended return based on a final court decision, protective claim filed in anticipation of a final court decision, or subsequent amended return \nsubsequent amended return based on a final court decision, protective claim filed in anticipation of a final court decision, or subsequent amended return \nrelating to adjustment from another source partnership examination, see the instructions to Form 8982 for further information.\nrelating to adjustment from another source partnership examination, see the instructions to Form 8982 for further information.\nPartner Alternative Procedure Under IRC §6225(c)(2)(B)\nInstead of filing a modification amended return to take into account its distributive share of all partnership adjustments, a relevant partner may choose \nthe alternative procedure in order to take into account its distributive share of all partnership adjustments. Each relevant partner choosing this option \nmust complete and sign Section B of Form 8982, Affidavit for Partner Modification Amended Return Under IRC §6225(c) (2)(A) or Partner Alternative \nProcedure Under IRC §6225(c)(2)(B). A Form 8982 for each partner listed in this part must be submitted as a related form to Form 8980 when Form \n8980 is submitted. If the IRS approves a modification for a partner alternative procedure under this section, the partnership may not request additional \nmodifications with respect to that partner or with respect to the partnership adjustment allocated to such partner.\nRequirements for the Alternative Procedure. The following are requirements in order for the IRS to approve the alternative procedure requested \nmodification request:\n• \nThe partner must electronically pay any tax due as a result of taking into account their distributive share of all partnership adjustments in the \nfirst affected year and all modification years. Any penalties, additions to tax, additional amounts and interest that would be required as if the \nrelevant partner filed an amended return must also be paid;\n• \nThe partner agrees to take into account adjustments to any of its tax attributes;\n• \nThe partner completes and signs Section B of Form 8982, and provides it to the PR.\n• \nThe PR must attach the completed Form 8982 to Form 8980 when the Form 8980 is submitted to the IRS.\nRefunds Not Allowed Under the Alternative Procedure. The alternative procedure does not include claims for refund. Therefore, under the alternative \nprocedure, a partner may not claim a refund. If a relevant partner, as a result of taking their distributive share of partnership adjustments into account, \nhas a refund due (whether in the first affected year or any other modification year), the relevant partner cannot use the alternative procedure to claim \na refund. Instead of choosing the alternative procedure, the relevant partner may choose to file an amended return under IRC section 6225(c)(2)(A) in \norder to claim a refund.\n", "17\nBinding Effect on Relevant Partner Tax Attributes. Any adjustments to tax attributes of any relevant partner which are affected by modification for \nthe alternative procedure are binding on the relevant partner with respect to the first affected year and all modification years. A failure to adjust any tax \nattribute is a failure to treat a partnership-related item in a manner which is consistent with the treatment of such item on the partnership return within \nthe meaning of section 6222. The provisions of section 6222(c) and applicable Regulations (regarding notification of inconsistent treatment) do not apply \nwith respect to such tax attributes.\nFull Payment Required. Electronic payment of any tax due, penalties, additions to tax, additional amounts, and interest due as a result of taking \ninto account all partnership adjustments in the first affected year and all modification years must be made, as if the partner were filing a modification \namended return(s). The electronic payment of all amounts due by the partner is a requirement in order for the modification request to be approved. A \nmodification request submitted under the alternative procedure is not a claim for refund. See “Refunds Not Allowed Under the Alternative Procedure” \nabove, for further information.\nSpecific Instructions\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Total number of relevant partners filing an amended return or choosing the alternative procedure under this modification request. Enter \nthe total number of relevant partners that filed an amended return or that chose the alternative procedure. This is a required field when this type \nof modification is requested. When the number of relevant partners is entered, the form will populate with the correct number of lines needed for \ncompletion.\nNote Regarding If Two Relevant Partners File a Joint Modification Amended Return or Choose the Alternative Procedure: If two partners of \nthe source partnership filed a joint original return then those partners must file a joint modification amended return (or jointly choose the alternative \nprocedure). In this case, only one Form 8982 needs to be completed. Include both partners (both spouses) on Form 8982 as included in the modification \namended return or alternative procedure. Both partners must also sign the Form 8982. For purposes of the partnership representative’s completion of \nForm 8980, each partner (although included in a joint return) must be listed on a separate line on Form 8980, Item E, Part I.\nColumns (1) and (2): Name of Partner & TIN of Partner. Both column (1) and column (2) are required fields for each relevant partner. List the \nname and Taxpayer Identification Number (TIN) of each relevant partner which has filed a modification amended return or has chosen the alternative \nprocedure. For each partner listed in columns 1 and 2, a Form 8982, Affidavit for Partner Modification Amended Return Filed Under Section 6225(c)(2)\n(A) or Partner Alternative Procedure Under IRC Section 6225(c)(2)(B), must be completed and signed by the partner, provided to the PR, and must be \nsubmitted as a related form to Form 8980 when Form 8980 is submitted.\nFor each partner listed in column (1), complete column (3) through column (8) as applicable and according to the following instructions: \nColumn (3a) & (3b): Check either Column 3a for Amended Return, or 3b for Alternative Procedure. Both columns 3a and 3b cannot be checked \nfor a relevant partner.\nColumn (3a): Amended Return: If the relevant partner listed in column 1 has filed a modification amended return pursuant to §6225(c)(2)(A), check the \nbox in column 3a. You must also attach a completed and signed Form 8982.\nColumn (3b): Alternative Procedure: If the relevant partner listed in column 1 has selected the alternative procedure pursuant to §6225(c)(2)(B), check \nthe box in column 3b. You must also attach a completed and signed Form 8982.\nColumn (3c): Check if Indirect Partner: If the relevant partner listed in column 1 is an indirect partner of the source partnership, check the box in \ncolumn 3c. Caution: By checking this box, you must ensure that all pass-through partners through which the indirect partner holds its interest in the \nsource partnership, are not taxable entities subject to Chapter 1 tax. If any of the pass-through partners through which the indirect partner holds its \ninterest in the source partnership are taxable entities subject to Chapter 1 tax, modification cannot be requested for such indirect partner unless the \npartnership also requests modification with respect to the adjustments resulting in Chapter 1 tax for the pass-through partner.\nPass-through Partners Only (Columns 3(d) through 3(f))\nCheck either Column 3d or 3f:\nColumn (3d): Not subject to Chapter 1 tax (therefore, using Treas. Reg. sections 301.6225-2(d)(2)(vi) and 301.6226-3(e)(4)(iii) to calculate its \npayment due): If the pass-through partner is:\n• \nFiling an amended return or selecting the alternative procedure, and\n• \nIs not a taxable entity subject to Chapter 1 tax and is therefore calculating any payment due in accordance with Treas. Reg. sections \n301.6225-2(d)(2)(vi) and 301.6226-3(e)(4)(iii), \nThen check the box in column 3d. Go to the instructions for column 3e. If the pass-through entity plans to apply modifications with respect to any of \nthe partners of the pass-through partner for purposes of the payment calculation pursuant to applicable Regulations, such modifications must be pre-\napproved by the IRS in order for the pass-through partner to take such modifications into account. See the instructions for Item D on how to request the \npre-approval (and do not check column 3e). Otherwise, if such modifications have already been approved by the IRS and the pass-through partner is \napplying the approved modifications to its payment calculation, then check column 3d and column 3e and go to the instructions for column 3e below.\nColumn (3e): If column 3d is checked: If column 3d is checked, and the pass-through partner is taking into account any pre-approved modifications \nwith respect to any of its partners for purposes of the pass-through partner’s payment calculation in accordance with Treas. Reg. sections 301.6225-\n2(d)(2)(vi) and 301.6226-3(e)(4)(iii), then check column 3e. In addition, you must attach a statement detailing the pre-approved modifications \ntaken into account, including the following information:\n• \nThe pass-through partner’s payment calculation per Treas. Reg. sections 301.6225-2(d)(2)(vi) and 301.6226-3(e)(4)(iii), including the \napproved modification amounts applied to the calculation; and\n• \nFor each approved modification applied, include the type of modification, identification of the relevant partners (name and TIN), and \nmodification amount. Such information must be consistent with the pre-approval information (regarding the approved modifications for any \npartners of the pass-through partner) that you received from the IRS.\nCaution: Only pre-approved modifications may be taken into account by the pass-through partner in calculating its payment due. If such modifications \nare applied to the payment calculation and not pre-approved by the IRS, the modification request relative to the pass-through partner amended return or \nalternative procedure will be denied. To request the pre-approval of modifications relating the partners of a pass-through partner, use Form 8980, Item D \nand follow the specific instructions for Item D.\n", "18\nColumn (3f): Subject to Chapter 1 tax: If the pass-through partner is:\n• \nFiling an amended return or selecting the alternative procedure, and\n• \nIs a taxable entity subject to Chapter 1 tax, Then check the box in column 3f.\nTIN of Partner. Re-enter the TIN of the relevant partner that was entered in column 2. This column is a continuation of requested information for the \npartner. Therefore, make sure the TIN entered here is the same TIN entered in column (2). Once the TIN is entered, continue entering the appropriate \ninformation for the partner in columns (4) through (8), as applicable. This is a required field. \nColumns (4) through (7): At least one entry in columns 4 through 7 must be entered for each partner listed.\nColumn (4): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 4 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Reallocation and Residual groupings. The amount entered \nin column 4 should be consistent with the total amount entered on Form 8982, Section A or B, Part III, B, column 2. Do not include adjustments to \nCreditable Expenditures or Credits in this column. Any amounts entered in column 4 should be consistent with the allocation information provided on \nForm 8980, Item C for such adjustments. Allocations of net negative adjustments resulting after subgroupings within the Reallocation and Residual \ngrouping should be included in column 7.\nColumn (5): Total Share of Creditable Expenditure Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 5 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Creditable Expenditure grouping. This includes decreases \nto creditable expenditures (including decreases to Creditable Foreign Tax Expenditures (CFTEs) which were included in the subgroupings within the \nCreditable Expenditures grouping). The amount entered in column 5 should be consistent with the total amount entered on Form 8982, Section A or \nB, Part III, column 3. Any amounts entered in column 5 should be consistent with the allocation information provided on Form 8980, Item C for such \nadjustments. Allocations of any net negative adjustments resulting after subgroupings (representing net increases to creditable expenditures) should be \nincluded in column 7.\nColumn (6): Total Share of Credit Grouping Adjustments (positive and negative adjustments). Enter in the appropriate subcolumn of column 6 \n(General or Specific – depending on which imputed underpayment such adjustments were included in), the total of each partner’s distributive share of \nall credit adjustments (positive and negative) which were included in the Credit Grouping per the NOPPA. The amount entered in column 6 should be \nconsistent with the total amount entered on Form 8982, Section A or B, Part III, column 4. Any amounts entered in column 6 should be consistent with \nthe allocation information provided on Form 8980, Item C for such adjustments.\nColumn (7): Total Share of Net Negative Adjustments. Include in column 7, the following amounts:\n• \nThe total of all allocations for each relevant partner which are net negative adjustments (resulting after subgrouping per the NOPPA) in the \nReallocation and Residual grouping; and\n• \nThe total of any net negative adjustments (resulting after subgrouping per the NOPPA) in the Creditable Expenditures grouping. A net negative \nadjustment in the Creditable Expenditures grouping is a net increase to Creditable Expenditures after subgrouping.\nThe amount entered in column 7 should be consistent with the total amount entered on Form 8982, Section A or B, Part III, column 5. Any amounts \nentered in column 7 should be consistent with the allocation information provided on Form 8980, Item C, for such adjustments.\nColumn (8): If Column (3b) Alternative Procedure is checked, enter the amount paid. Include in column 8 the total amount paid (including all tax, \npenalties, additions to tax, additional amounts, and interest. The amount entered in column 8 should be the same amount reported on Form 8982, \nSection B, Part III, Line 6.\nPart II – Tax-Exempt Partners Under IRC Section 6225(c)(3) and Foreign Partners Exempt under Section 501(a)\nUnder section 6225(c)(3), an imputed underpayment will be determined without regard to the portion of adjustments that the partnership demonstrates \nis allocable to a reviewed year relevant partner that is a tax-exempt entity under section 168(h)(2). Use this part of Form 8980 to request modifications \nto the partnership’s imputed underpayment(s) for a tax-exempt partner and for a relevant foreign partner exempt from tax under section 501(a). A Form \n8983, Certification of Partner Tax-Exempt Status for Modification Under Section 6225(c)(3), must be completed and signed by the partner, provided to \nthe PR, and must be submitted as a related form to Form 8980 when Form 8980 is submitted. There should be a completed Form 8983 submitted for \neach partner listed in this part.\nModifications for Foreign Tax-Exempt Partners other than exemptions under Section 501(a) Should Use Item E, Part VIII (not Part II). \nPartnerships requesting modification for foreign partners based on partnership adjustments consisting of income that is exempt by statute other than \nSection 501(a) (e.g., interest received from certain portfolio debt investments per §871(h)) should not use Part II. Instead, use Part VIII to request such \nmodifications. See the instruction to Part VIII, Foreign Partners: Modification Pursuant to Tax Treaty Claims & Statutory Exemptions other than Section \n501(a), for more information.\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Total relevant tax-exempt partners under this modification request. Enter the total number of relevant partners that are tax-exempt partners \nincluded in this modification request. This is a required field when this type of modification is requested. When the number of relevant partners is \nentered, the form will populate with the correct number of lines needed for completion.\nColumns (1) and (2): Name of Partner & TIN of Partner. Both column (1) and column (2) are required fields. List the name and Taxpayer Identification \nNumber (TIN) of each relevant partner that is a tax-exempt partner. For each partner listed in columns 1 and 2, a Form 8983, Certification of Partner Tax-\nExempt Status for Modification Under Section 6225(c)(3), must be completed and signed by the partner, provided to the PR, and must be submitted as \na related form to Form 8980 when Form 8980 is submitted.\nColumns (3) through (6): At least one entry in columns 3 through 6 must be entered for each partner listed.\nColumn (3): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 3 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Reallocation and Residual groupings. The amount entered \nin column 3 should be consistent with the total amount entered on Form 8983, Part III, column 2. Do not include adjustments to Creditable Expenditures \nor Credits in this column. Any amounts entered in column 3 should be consistent with the allocation information provided on Form 8980, Item C for such \nadjustments. \n", "19\nColumn (4): Total Share of Creditable Expenditure Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 4 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Creditable Expenditure grouping. The amount entered \nin column 4 should be consistent with the total amount entered on Form 8983, Part III, column 3. This includes decreases to creditable expenditures \n(including decreases to Creditable Foreign Tax Expenditures (CFTEs) which were included in the subgroupings within the Creditable Expenditures \ngrouping. Any amounts entered in column 4 should be consistent with the allocation information provided on Form 8980, Item C for such adjustments.\nColumn (5): Total Share of Credit Grouping Adjustments (positive and negative adjustments). Enter in the appropriate subcolumn of column 5 \n(General or Specific – depending on which imputed underpayment such adjustments were included in), the total of each partner’s distributive share of \nall credit adjustments (positive and negative) which were included in the Credit Grouping per the NOPPA. The amount entered in column 5 should be \nconsistent with the total amount entered on Form 8983, Part III, column 4. Any amounts entered in column 5 should be consistent with the allocation \ninformation provided on Form 8980, Item C for such adjustments.\nColumn (6): Adjustments which are tax-exempt income or related to tax-exempt income. Include in column 6 the portion of column (3) amounts \nwhich is tax-exempt income or related to tax-exempt income. The amount entered in column 6 should be the same amount reported on Form 8983, Part \nIII, B, column 6. This is a required field.\nPart III – Applicable Highest Tax Rates of Partners Under IRC Section 6225(c)(4)\nUnder section 6225(c)(4), a portion of the adjustment included in the imputed underpayment will be determined with a lower rate of tax if such rate is \nlower than the highest rate of tax in effect for the reviewed year, and if the portion of the imputed underpayment is allocable to a partner which:\n• \nIs a C corporation; or\n• \nIn the case of an adjustment consisting of a capital gain or qualified dividend, a partner which is an individual. An S corporation partner is \ntreated as an individual in this circumstance.\nIn general, except in the case of rate modifications involving special allocations, the portion of the adjustment to which a lower rate of tax applies is \ndetermined by reference to a partner’s distributive share of items to which the imputed underpayment relates.\nRate Modification Involving Special Allocations. If an imputed underpayment is calculated based on more than one adjustment and the determination \nof a partner’s distributive share of such adjustments differs among adjustment items, the partnership must select which method it will use for \ndetermining each partner’s distributive share to which the lower rate applies. You must check one box indicating which method, in Line B, \nbelow. See Line B, for further information.\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Total number of direct and indirect reviewed year partners for which tax rate modification is requested. Enter the total number of relevant \npartners for which tax rate modification is requested. This is a required field when this type of modification is requested. When the number of \nrelevant partners is entered, the form will populate with the correct number of lines needed for completion.\nB. Special Allocations of Adjustments Within a Partner’s Distributive Share Subject to Rate Modification. If any rate modification is being \nrequested with respect to any relevant partner that has more than one adjustment within a distributive share that is specially allocated, check the special \nallocation box next to column 4 for the relevant partner. In addition, the partnership must check one of the boxes on Line B, to select one of the following \nmethods for which it is using to determine the distributive share item which is subject to a lower rate:\nCheck the box on Line B for which method the partnership is using to determine the partner’s distributive share to which the lower rate \napplies:\nAlternative Option per section 6225(c)(4)(B)(i): Check the box for this option if the total distributive share amount that is subject to a lower rate is \ndetermined based on the actual special allocations of the various adjustments within the distributive share item. For each relevant partner with a special \nallocation, be sure to check the box within column 4. For the total amount to be listed in column 4 for each relevant partner, Form 8980, Item C should \ncontain the allocation detail for each adjustment behind the total listed in column 4. If more than one rate is being requested for a relevant partner, only \nlist the relevant partner once in Part III and attach a schedule detailing each allocation amount subject to a lower rate, the alpha code relating to the \nincome type for each such allocation, and the associated lower rate pertaining to each allocation.\nReviewed Year liquidation rule per section 6225(c)(4)(B)(ii): Check the box for this option if the total distributive share amount that is subject to a \nlower rate is determined based on the amount of net gain or loss to the partner that would have resulted if the partnership had sold all of its assets at \ntheir fair market value as of the close of the partnership’s reviewed year, appropriately adjusted to reflect any modification with respect to any relevant \npartner that has an approved modification other than rate modification. For each relevant partner with a special allocation, be sure to check the box \nwithin column 4. If more than one rate is being requested for a relevant partner, only list the relevant partner once in Part III, and attach a schedule \ndetailing each allocation amount subject to a lower rate, the alpha code relating to the income type for each such allocation, and the associated lower \nrate pertaining to each allocation. In order to support the total amount listed in column 4, the following information must be provided with the modification \nrequest:\n• \nFor each relevant partner, a schedule detailing the specially allocated adjustments within the distributive share subject to rate modification;\n• \nThe partnership’s calculation of the partners’ book capital accounts through the end of the reviewed year (tax year ended date entered on \nForm 8980, Line 3); and\n• \nThe partnership’s calculation of the asset liquidation gain or loss.\nColumns (1) and (2): Name of Partner & TIN of Partner. Both column (1) and column (2) are required fields for each relevant partner. List the \nname and Taxpayer Identification Number (TIN) of each direct or indirect relevant partner for which the partnership is requesting modification under this \nsection.\nColumn (3): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 3 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Reallocation and Residual groupings. Do not include \nadjustments to Creditable Expenditures or Credits in this column. Any amounts entered in column 3 should be consistent with the allocation information \nprovided on Form 8980, Item C for such adjustments. This is a required field.\nColumn (4): Amounts in column (3) subject to rate reduction. This is a required field. For any special allocations, check the box and see instructions. \nEnter in the appropriate subcolumn of column 4 (General or Specific – depending on which imputed underpayment the adjustments are applied to), \nthe amount of an adjustment from column (3) that is subject to an alternative lower rate of tax than the highest rate in effect. For example, for individual \nor S corporation partners this is long-term capital gains subject to lower capital gains rates or qualified dividends subject to the qualified dividends \nrate. For C corporation partners this is income subject to lower corporate income tax rate when the highest rate in effect is greater than the highest \n", "20\ncorporate tax rate. If such amount entered in column 4 includes a specially-allocated adjustment, check the “special allocation” box within column 4 \nfor the relevant partner. Be sure to attach the required information for each relevant partner, depending on which method the partnership is selecting \nfor the determination of the distributive share amounts subject to the lower rate. See Line B, Special Allocations of Adjustments Within a Partner’s \nDistributive Share Subject to Rate Modification, above for further information on what to attach to Form 8980. Also, make sure that each specially \nallocated adjustment detailed on Form 8980, Item C has the box for “Special Allocation” checked on the line for the relevant partner.\nColumn (5): Income Code: This is a required field. For each amount listed in Column 4, enter the alpha code associated with the type of income listed. \nUse the following alpha codes: \n• \nGeneral long-term capital gains, enter code: CG-GEN\n• \nSec. 1250 capital gains, enter code: CG-1250\n• \nCapital gains on collectibles, enter code: CG-COLL\n• \nQualified dividends, enter code: QDIV\n• \nOrdinary income, enter code: ORDINC\n• \nOther income, enter code: = OTHER, and attach a statement detailing the type of income\nColumn (6): Reduced tax rate applicable to amount(s) in column (6). This is a required field. Include in column 6 the tax rate(s) that should be \napplied to the amounts listed in column 4. Note: If more than one rate is being requested for a relevant partner, only list the relevant partner once in Part \nIII, and attach a schedule detailing each allocation amount subject to a lower rate, the alpha code relating to the income type for each such allocation, \nand the associated lower rate pertaining to each allocation. This field allows numeric characters with a decimal (if applicable). \nPart IV – Passive Activity Losses of Publicly Traded Partnerships (PTPs) Under IRC Section 6225(c)(5)\nUnder section 6225(c)(5), in the case of a publicly traded partnership (PTP), the imputed underpayment may be determined without regard to the portion \nof the adjustment that the partnership demonstrates would be reduced by a specified passive activity loss which is allocable to a specified partner or \nqualified relevant partner. If a PTP requests this type of modification, Form 15028 must be completed and signed by the PR and must be submitted as a \nrelated form to Form 8980 when Form 8980 is submitted.\nA publicly traded partnership is defined under section 469(k)(2) as a partnership if interests in such partnership are traded on an established securities \nmarket, or interests in such partnership are readily tradable on a secondary market (or the substantial equivalent thereof).\nSee “Definitions” in these instructions for the definition of other terms used in this part.\nNotification Requirement to Specified Partners and Qualified Relevant Partners to Reduce Suspended Passive Loss Carryovers. The source \npartnership must complete and sign Form 15028 (Certification of Publicly Traded Partnership to Notify Specified Partners and Qualified Relevant \nPartners for Approved Modifications Under Section 6225(c)(5)), and it must be submitted as a related form to Form 8980 when Form 8980 is submitted. \nForm 15028 is used by the source partnership to certify to the IRS that the source partnership will report to each specified partner or qualified relevant \npartner the amount of the relevant partner’s reduction to its suspended passive loss carryover, based on the source partnership’s approved modification \nwhich takes such specified and qualified relevant partner suspended losses into account. Both Form 8980, Item E, Part IV and Form 15028 are \ncompleted as if the IRS will approve the modification based on the relevant partner amounts entered on Form 8980, Part IV, column 9 (and Form 15028, \nPart II, column 7). See the instruction to Form 15028 for additional information.\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Total number of specified partners or qualified relevant partners under this modification request. Enter the total number of specified partners \nor qualified relevant partners for which the partnership is requesting modification under this section. This is a required field when this type of \nmodification is requested. When the number of partners is entered, the form will populate with the correct number of lines needed for completion.\nColumns (1) and (2): Name of Partner & TIN of Partner. Both column (1) and column (2) are required fields for each relevant partner. List the \nname and Taxpayer Identification Number (TIN) of each specified or qualified relevant partner for which the partnership is requesting modification under \nthis section.\nColumn (3): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 3 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Reallocation and Residual groupings. Do not include \nadjustments to Creditable Expenditures or Credits in this column. Any amounts entered in column 3 should be consistent with the allocation information \nprovided on Form 8980, Item C for such adjustments. This is a required field.\nColumn (4): Total Share of Creditable Expenditure Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 4 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Creditable Expenditure grouping. This includes decreases \nto creditable expenditures (including decreases to Creditable Foreign Tax Expenditures (CFTEs) which were included in the subgroupings within the \nCreditable Expenditures grouping. Any amounts entered in column 4 should be consistent with the allocation information provided on Form 8980, Item C \nfor such adjustments.\nColumn (5): Total Share of Credit Grouping Adjustments (positive and negative adjustments). Enter in the appropriate subcolumn of column 5 \n(General or Specific – depending on which imputed underpayment such adjustments were included in), the total of each partner’s distributive share \nof all credit adjustments which were included in the Credit Grouping per the NOPPA. Any amounts entered in column 5 should be consistent with the \nallocation information provided on Form 8980, Item C for such adjustments.\nSection 469 Specified Passive Activity Loss Carryover\nTIN of Partner: Re-enter the TIN of the relevant partner that was entered in column 2. This column is a continuation of requested information for \nthe partner. Therefore, make sure the TIN entered here is the same TIN entered in column (2). Once the TIN is entered, continue entering the \nappropriate information for the partner in columns (6) through (10), as applicable. This is a required field. \nColumn (6): Affected Year Loss. Enter in column 6, the partner’s section 469(k) passive activity loss at the end of the first affected year (affected year \nloss). This amount is the section 469(k) loss calculated without taking into account the partner’s distributive share of partnership adjustments for the \nreviewed year. The amount entered in column 6 should be consistent with the amount entered on Form 15028, Part II, column 3. All numbers entered in \nthis column must be entered as negative numbers.\nColumn (7a) through (7c): Utilization of Affected Year Loss- Year and Amount. Enter in Columns 7a through 7c the partner’s taxable year(s) and \nthe respective portion of the affected year loss (reported in column 6) that was utilized in a taxable year after the first affected year to offset income or \ngain relating to ownership disposition of its interest in the PTP during the adjustment year or any other year. All numbers entered in this column must be \nentered as positive numbers.\n", "21\nColumn (7d): Balance. If any amounts are entered in columns 7a, 7b, or 7c, subtract such amounts from the amount in column 6 and enter the result \nin column 7d. The amount entered in column 7d should be consistent with the amount from Form 15028, Part II, column 4. All numbers entered in this \ncolumn must entered as negative numbers or zero.\nColumn (7e): Specified Passive Activity Loss at the End of the Most Recent Year for Which PTP has filed a return. Enter in column 7e, the \npartner’s section 469(k) passive activity loss at the end of the most recent taxable year for which the PTP has filed a return. The amount entered in \ncolumn 7e should be consistent with the amount from Form 15028, Part II, column 5. All numbers entered in this column must be entered as negative \nnumbers.\nColumn (8): Specified Passive Activity Loss. Enter the lesser of column 6 or column 7e. The amount entered in column 8 should be consistent with \nthe amount from Form 15028, Part II, column 6. All numbers entered in this column must be entered as negative numbers. This is a required field.\nEffect of Modification. \nColumns 9 and 10 should be completed under the assumption that the IRS will approve the requested modification. \nColumn (9): Reduction in Carryover. Enter in column 9, the reduction to the partner’s carryover as a result of the modification under IRC section \n6225(c)(5) whereby the partnership’s imputed underpayment was determined without regard to the partner’s distributive share of partnership \nadjustments that would be reduced by a specified passive activity loss. The amount entered should generally be the amount entered in column 3, unless \nthe amount in column 3 exceeds the amount in column 8. In that case, only enter the amount from column 8 in column 9. The amount entered in column \n9 cannot exceed the amount entered in column 8. The amount entered in column 9 should be consistent with the amount from Form 15028, Part II, \ncolumn 7. All numbers entered in this column must be entered as positive numbers. This is a required field.\nColumn (10): Adjusted Balance in Carryover. Subtract the amount in column 9 from the amount in column 8 and enter the result in column 10. The \namount entered in column 10 should be consistent with the amount from Form 15028, Part II, B, column 8. All numbers entered in this column must \nentered as negative numbers or zero. This is a required field.\nPart V – Modification of the Number and Composition of Imputed Underpayments Under Applicable Regulations\nThe imputed underpayment is determined, in general, according to Section 6225(b). Rules on grouping, subgrouping and netting are provided in \napplicable Regulations.\nUnder applicable Regulations, in general, a partnership may request that the IRS:\n• \nInclude one or more partnership adjustments in the general imputed underpayment per the NOPPA into one or more specific imputed \nunderpayments;\n• \nInclude one or more partnership adjustments in a particular grouping or subgrouping different from the NOPPA;\n• \nNot apply certain restrictions and limitations (by proving that such restrictions or limitations do not apply) so that one or more partnership \nadjustments per the NOPPA can be subgrouped with other adjustments. \nUse Part V of Form 8980 to request any modifications to the number and composition of the imputed underpayment(s). For all requests in Part V, you \nmust provide supporting documents to substantiate your request. \nSee applicable Regulations for examples.\nRequest for Particular Treatment Regarding Limitations or Restrictions. The subgrouping rules provide that an adjustment is subgrouped according \nto how the adjustment would be required to be taken into account separately under section 702(a) or any other provision of the Code or regulations \napplicable to the partnership-related item. Therefore, if any adjustment could be subject to any preference, limitation, or restriction under the Code (or \nnot allowed, in whole or in part, against ordinary income) if taken into account by any person, the adjustment is placed in a separate subgrouping from all \nother adjustments within the grouping. However, if a partnership can substantiate to the satisfaction of the IRS that such limitations or restrictions do not \napply, then one or more partnership adjustments may be treated as if no limitations or restrictions apply, resulting in such adjustments being subgrouped \nwith other adjustments. See applicable Regulations for a more detailed example. Use Part V of Form 8980 to request this type of modification. Attach a \nstatement detailing the adjustments and relevant partners relative to the request, and provide documents supporting the claim that such restrictions or \nlimitations do not apply for each relevant partner. You must provide documentation substantiating your request.\nSee the “Definitions” section earlier in these instruction for the definition of partnership adjustments, groupings, subgroupings, general imputed \nunderpayment, and specific imputed underpayment.\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Explanation of Modifications requested regarding the number and composition of imputed underpayments. For each modification requested \nin Part V, provide a detailed explanation of the requested modification including which partnership adjustments, relevant partners, grouping and \nsubgrouping information per NOPPA and per the request. Attach additional schedules, in order to adequately explain the requested modifications. \nBe sure to also provide supporting documents substantiating your request.\nAttach a statement if additional space is needed.\nB. Total Number of adjustments affected by this modification request. Enter the total number of adjustments that are involved in this modification \nrequest.\nC. Enter the total number of specific imputed underpayments being requested. This is a required field. Note: If a specific imputed underpayment \nis not being requested, then enter the number of partners affected by the requested modification. When the number of specific imputed underpayments \nis entered, the form will populate with the correct number of lines needed for completion. In general, each line entered in Part V pertains to each \nspecific imputed underpayment being requested. Refer to the Example on the fillable PDF before completing the lines and columns in Part V.\nColumns (1) through (4) - Adjustments & Imputed Underpayments per NOPPA \nEach line entered in Part V pertains to each specific imputed underpayment being requested. If no specific imputed underpayment is being \nrequested, then enter “See attached” under column (1) See the Example before completing the lines and columns in Part V.\nColumn (1): Adjustments: This is a required field. Enter a description of the partner or group of partners pertaining to the adjustments that were \nincluded in the NOPPA, for which you are requesting one or more specific imputed underpayments. Note: If no specific imputed underpayment \nis being requested, then enter “See attached” under column (1) for each relevant partner, and attach a schedule detailing the requested \nmodification. Be sure to also provide supporting documents substantiating your request.\nColumn (2): General: For all adjustments described in column 1, enter the amount of such adjustments which were included in the general imputed \nunderpayment per the NOPPA.\n", "22\nColumn (3): Specific: For all adjustments described in column 1, enter the amount of such adjustments, if any, which were already included in a specific \nimputed underpayment per the NOPPA.\nColumn (4): Negative adjustments: Enter the total amount of net negative adjustments per the NOPPA, which resulted after groupings, subgroupings \nand netting. Enter all numbers in this column as a negative amount.\nColumns (5) through (8) - Groupings/Subgroupings per NOPPA\nColumn (5) Reallocation; Column (6) Residual; Column (7) Creditable Expenditures; and Column (8) Credits: For the adjustments listed in \ncolumns 2, 3, or 4, enter the amount of such adjustments in the appropriate grouping column 5, 6, 7, and 8, (Reallocation, Residual, Creditable \nExpenditure, or Credits), as grouped per the NOPPA. For each amount listed per grouping column, detail the amount and the subgrouping description \nnext to the amount. (See Example in this section for an illustration). All fields in columns 5 through 8 are text type fields. Therefore, you may enter both \nnumeric and alpha characters.\nColumns (9) through (12) - Specific Imputed Underpayments Requested for Adjustment Amounts in Column (2), (3), and (4)\nColumn (9) Reallocation; Column (10) Residual; Column (11) Creditable Expenditures; Column (12) Residual: For the adjustments detailed in \ncolumns 5, 6, 7 and 8, similarly detail the adjustments being requested to be placed in a specific imputed underpayment. For each amount listed per \ngrouping column 9, 10, 11 and 12, detail the amount and the subgrouping description next to the amount. (See Example in this section for an illustration). \nNote that if more than one specific imputed underpayment is being requested, each specific imputed underpayment should be entered on a separate \nline. All fields in columns 5 through 8 are text type fields. Therefore, you may enter both numeric and alpha characters. Attach additional schedules if \nnecessary. Note: If no specific imputed underpayment is being requested, then enter “N/A” See attached” under column (1) for each relevant \npartner, and attach a schedule detailing the requested modification and provide supporting documents.\nPart VI – IRC Section 860(b) Qualified Investment Entity (QIE) Partners Under Treas. Reg. Sec. 301.6225-2(d)(7)\nUnder applicable Regulations, a partnership may request modification based on partnership adjustments allocated to a relevant partner where the \nmodification is based on deficiency dividends distributed as described in section 860(f) by a relevant partner that is a qualified investment entity (QIE) \ndefined under IRC section 860(b). Such modification is only available to the extent that the deficiency dividends take into account the partnership \nadjustments that are also adjustments within the meaning of section 860(d)(1) or (d)(2) (whichever applies).\nQualified Investment Entity (QIE) Partner Defined. A QIE is defined under section 860(b) and includes both a regulated investment company (RIC), \nand a real estate investment trust (REIT).\nSubstantiation of QIE Partner’s Determination Under IRC Section 860(e)(4) and Documentation of Deficiency Dividends. The partnership must \nprovide substantiation of the determination described in section 860(e)(4) either by providing:\n• \nA copy of a closing agreement entered into by the QIE partner pursuant to section 7121 and applicable regulations (modification for partner \nclosing agreements); or \n• \nA copy of Form 8927 (Determination Under Section 860(e)(4) by a Qualified Investment Entity) that was properly completed and filed by the \nRIC or REIT partner pursuant to section 860(e)(4). \nIn the case of a closing agreement, the determination date is the date in which the closing agreement is approved by the IRS. In the case of Form 8927, \nthe determination date and the amount of the deficiency dividends actually paid, will be substantiated by the partnership providing a copy of Form 976 \n(Claim for Deficiency Dividends Deduction by a Personal Holding Company, Regulated Investment Company, or Real Estate Investment Trust) properly \ncompleted by or on behalf of the QIE pursuant to section 860(g), together with a copy of each of the required attachments to Form 976.\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Total number of relevant Qualified Investment Entity partners for this modification request. Enter the total number of relevant QIE partners for \nwhich the partnership is requesting modification. This is a required field when this type of modification is requested. When the number of partners \nis entered, the form will populate with the correct number of lines needed for completion.\nColumns (1) and (2): Name of Each RIC or REIT (QIE) Partner & TIN of Partner. Both column (1) and column (2) are required fields for each \nrelevant partner. List the name and Taxpayer Identification Number (TIN) of each direct or indirect QIE partner for which the partnership is requesting \nmodification under this section. Both Columns 1 and 2 are required fields. \nColumn (3): Type of QIE Partner: Use the drop-down menu to select the type of qualified investment entity (“RIC” or “REIT”) for the relevant partner \nentered in column 1.\nColumn (4): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 4 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Reallocation and Residual groupings. Do not include \nadjustments to Creditable Expenditures or Credits in this column. Any amounts entered in column 4 should be consistent with the allocation information \nprovided on Form 8980, Item C for such adjustments.\nColumn (5): Total Share of Creditable Expenditure Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 5 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Creditable Expenditure grouping. This includes decreases \nto creditable expenditures (including decreases to Creditable Foreign Tax Expenditures (CFTEs)) which were included in the subgroupings within the \nCreditable Expenditures grouping. Any amounts entered in column 5 should be consistent with the allocation information provided on Form 8980, Item C \nfor such adjustments.\nColumn (6): Total Share of Credit Grouping Adjustments (positive and negative adjustments). Enter in the appropriate subcolumn of column 6 \n(General or Specific – depending on which imputed underpayment such adjustments were included in), the total of each partner’s distributive share of \nall credit adjustments (positive and negative) which were included in the Credit Grouping per the NOPPA. Any amounts entered in column 6 should be \nconsistent with the allocation information provided on Form 8980, Item C for such adjustments.\nColumn (7): Amount of Tax Deficiency. Enter the amount from Form 976, Line 1 relative to the QIE partner’s allocable share of partnership \nadjustments. If a Form 976 was not filed by the QIE partner, enter the amount of tax deficiency per the QIE partner’s closing agreement. Note: See \n“BBA Partner Payments Related to Requested Modifications” under the General Instructions for information on how partner payments must be \nidentified at the time payments are made.\nColumn (8): Tax Deficiency Amount Paid. Enter the amount from Form 976, Line 3a. If a Form 976 was not filed by the QIE partner, enter the amount \nof tax paid under the partner’s closing agreement.\n", "23\nColumn (9): Deficiency Dividend Distributed: Cash. For QIE partners that filed Form 976, enter the amount from Form 976, Line 8a.\nColumn (10): Deficiency Dividend Distributed: FMV of Other Property. For QIE partners that filed Form 976, enter the amount from Form 976, Line \n8b(1).\nColumn (11): Amount Claimed as a Deduction for Deficiency Dividends. For QIE partners that filed Form 976, enter the amount from Form 976, \nLine 9a.\nPart VII – Partner Closing Agreements Under Treas. Reg. Sec. 301.6225-2(d)(8)\nUnder applicable Regulations, a partnership may request modification based on partnership adjustments which were included in closing agreement \npursuant to section 7121 entered into by the IRS and the partnership or any relevant partner, or both if appropriate. Any partnership adjustment that \nis taken into account under such closing agreement and for which any required payment under the closing agreement is made, will not be taken into \naccount in determining the imputed underpayment. Generally, if the IRS approves a modification based on a relevant partner’s closing agreement under \nthis section, additional modifications with respect to that partner will not be approved.\nCaution: Closing agreement modification is not permitted for an AAR.\nNote: Use Part VII only for partner closing agreements. If the source partnership (rather than the partners, individually) entered into a closing \nagreement, do not use Part VII. Instead, use Part IX, Other Modifications, to request modification based on the source partnership closing agreement.\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Enter the total number of relevant partners with closing agreements under this modification request. This is a required field when this type \nof modification is requested. When the number of partners is entered, the form will populate with the correct number of lines needed for completion.\nColumns (1) and (2): Name of Partner & TIN of Partner. Both column 1 and column 2 are required fields for each relevant partner. List the name \nand Taxpayer Identification Number (TIN) of each direct or indirect partner for which the partnership is requesting modification under this section. Both \nColumns 1 and 2 are required fields.\nColumns (3) through (6): At least one entry in columns 3 through 6 must be entered for each partner listed.\nColumn (3): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 3 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Reallocation and Residual groupings which were included \nunder the closing agreement. Do not include adjustments to Creditable Expenditures or Credits in this column. Any amounts entered in column 3 should \nbe consistent with the allocation information provided on Form 8980, Item C for such adjustments. Allocations of net negative adjustments resulting after \nsubgroupings within the Reallocation and Residual grouping should be included in column 6.\nColumn (4): Total Share of Creditable Expenditure Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 4 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Creditable Expenditure grouping which were included \nunder the closing agreement. This includes decreases to creditable expenditures (including decreases to Creditable Foreign Tax Expenditures (CFTEs) \nwhich were included in the subgroupings within the Creditable Expenditures grouping. Any amounts entered in column 4 should be consistent with the \nallocation information provided on Form 8980, Item C for such adjustments. Allocations of any net negative adjustments resulting after subgroupings \n(representing net increases to creditable expenditures) should be included in column 6.\nColumn (5): Total Share of Credit Grouping Adjustments (positive and negative adjustments). Enter in the appropriate subcolumn of column 5 \n(General or Specific – depending on which imputed underpayment such adjustments were included in), the total of each partner’s distributive share of \nall credit adjustments (positive and negative) which were included in the Credit Grouping per the NOPPA and which were included under the closing \nagreement. Any amounts entered in column 5 should be consistent with the allocation information provided on Form 8980, Item C for such adjustments.\nColumn (6): Total Share of Net Negative Adjustments. Include in column 6, the following amounts, if included under the closing agreement:\n• \nThe total of all allocations for each specified partner which are net negative adjustments (resulting after subgrouping per the NOPPA) in the \nReallocation and Residual grouping; and\n• \nThe total of any net negative adjustments (resulting after subgrouping per the NOPPA) in the Creditable Expenditures grouping. A net negative \nadjustment in the Creditable Expenditures grouping is a net increase to Creditable Expenditures after subgrouping.\nAny amounts entered in column 6 should be consistent with the allocation information provided on Form 8980, Item C, for such adjustments.\nColumn (7): Amount of Tax Paid. Include in column 7 the amount of tax paid with the partner’s closing agreement. If no tax was paid with the \nclosing agreement, enter zero. This is a required field. Note: See “BBA Partner Payments Related to Requested Modifications” under the General \nInstructions for information on how partner payments must be identified at the time payments are made.\nColumn (8): Amount of Penalty Paid. Include in column 8 the amount of any penalty paid with the partner’s closing agreement.\nColumn (9): Date Paid. Enter the date in which the tax and any penalties were paid.\nColumn (10): Other Modification Year(s) included in the closing agreement. List any other tax years which were included in the partner’s closing \nagreement.\nColumn (11): Amount of Tax Paid for Other Modification Year(s). For any year listed in column 10, enter in column 11 the amount of tax paid relative \nto the other modification year included in the partner’s closing agreement.\nPart VIII – Foreign Partners: Modification Pursuant to Tax Treaty Claims & Statutory Exemptions Other Than \nSection 501(a)\n(For modification requests involving domestic partners that are tax-exempt and foreign partners that are tax-exempt under Section 501(a): \nDo not use Part VIII for modification requests involving domestic partners that are tax-exempt and foreign partners that are tax-exempt under Section \n501(a). Instead, use Part II of Form 8980, and the supporting attachment Form 8983, Certification of Partner Tax-Exempt Status for Modification Under \nIRC §6225(c)(3).)\nModification Pursuant to Tax Treaty Claims: Under applicable Regulations, a partnership may request modification based on a relevant partner’s \ndistributive share of an adjustment to a partnership-related item if, in the reviewed year if: (1) the relevant partner was a foreign person qualified under \nan income tax treaty with the United States for a reduction or exemption from tax with respect to such partnership-related item; or (2) the partnership \nitself was so qualified with respect to such item.\n", "24\nIf requesting this modification, complete Part VIII, columns 1 through 3, and columns 4a through 4e. (Do not complete column 5)\nModification Based on Statutory Exemption other than section 501(a): For modification requests relating to a foreign partner that is exempt by \nstatute due to a Code-based exemption (other than section 501(a)), modification should be requested based on a relevant partner’s distributive share of \nan adjustment to a partnership-related item by using Part VIII, columns 1 through 3, and columns 5a and 5b. (Do not complete columns 4a through 4e).\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Total number of relevant partners included under this modification request. This is a required field when this type of modification is \nrequested. When the number of partners is entered, the form will populate with the correct number of lines needed for completion.\nColumns (1) and (2): Name of Partner & TIN of Partner. Both column 1 and column 2 are required fields for each relevant partner. List the \nfull name and Taxpayer Identification Number (TIN) of each relevant foreign partner (direct or indirect) for which the source partnership is requesting \nmodification based on partner tax treaty claims or statutory exemptions other than section 501. Both Columns 1 and 2 are required fields.\nFor each partner listed in column (1) and (2), complete column (3), and either columns 4a through 4e (for tax treaty claims) or columns 5a and \n5b (for statutory exemptions other than Section 501(a)), according to the following instructions:\nColumn (3): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 3 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments within the Reallocation and Residual groupings (resulting after subgrouping per the NOPPA). Do not include \nadjustments to Creditable Expenditures or Credits in this column. Any amounts entered in column 3 should be consistent with the allocation information \nprovided on Form 8980, Item C for such adjustments. This is a required field.\nNote for Columns (4a) through (5b): For each partner listed, you must complete either Columns 4a through 4e (Tax Treaty Modification) or Columns \n5a and 5b (Statutory Exemptions).\nModification For Foreign Partner Tax Treaty Claims (Columns 4a through 4e) \nColumn (4a): Country of Residence. Use the drop-down menu to select the relevant partner’s country of residence.\nColumn (4b): Treaty Rate. Enter the percentage rate of withholding pertaining to the portion of income for which the tax treaty benefits are claimed, to \nbe entered in column 4e. This field allows numeric characters with a decimal (if applicable).\nColumn (4c): Treaty article and paragraph. Enter the article and paragraph number of the tax treaty provision for the tax treaty indicated in column 4a.\nColumn (4d): Type of income pertaining to the treaty benefit identified in column 4c. Enter the description of the specific type of income pertaining \nto the treaty benefit indicated in column 4c.\nColumn (4e): Enter the portion of Column (3) representing income for which the partner is claiming tax treaty benefits for payments subject \nto withholding under Chapter 3. Enter the amount of the partner’s distributive share of partnership adjustment which is subject to the treaty benefit \nindicated in column 4c.\nExample 1: A partnership originally reported U.S. source dividends as a Return of Capital (ROC). ROC is not subject to Chapter 3 withholding. Upon \nexam, the IRS determined that the U.S. source dividends were incorrectly characterized as ROC and should have been reported as ordinary dividends. \nThe distributive share of the adjustment of ordinary dividends to Partner A, an individual resident of the United Kingdom, is $1,000. Absent a treaty, \nPartner A would be subject to the statutory withholding of 30%. However, partner A has a valid Form W-8BEN on file with the partnership/withholding \nagent claiming tax treaty benefits as a resident of the UK, which is subjected to the treaty rate of 15%. Since the partnership’s imputed underpayment \nis calculated at the default tax rate of 37%, the partnership requests modification with regard to foreign Partner A’s tax treaty benefit for U.S. source \nordinary dividends at a rate of 15%. The partnership would complete Form 8980, Part VIII, as follows to request the modification based on Partner A:\nD \nR \nA \nF \nT \nC \nO \nP \nY\nN \nO \nT \nF \nO \nR \nR \nE \nL \nE \nA \nS \nE\nPage 12 of 14\nPage 12 of 14\nPart VIII - Foreign Partners: Modification Pursuant to Tax Treaty Claims Under Applicable Regulations & Statutory Exemptions Other Than Section 501(a)\nA. Enter the total number of reviewed year partners included under this modification request\n 1 \n(1) \nName of Partner\n(2) \nTIN of Partner \n(3) \nTotal Share of \nReallocation & Residual \nGrouping Adjustments \n(net positive \nadjustments only)\nGeneral\nSpecific\nTax Treaty Modification\n(4a) \nCountry of \nResidence\n(4b) \nTreaty \nRate\n(4c) \nTreaty \nArticle and \nParagraph\n(4d) \nType of Income \npertaining to the treaty \nbenefit identified in \ncolumn (4c)\nGeneral\nSpecific\n(4e) \nEnter the portion of column \n(3) representing Income for\nwhich the partner is claiming\ntax treaty benefits for \npayments subject to \nwithholding under Chapter 3\nGeneral\nSpecific\nStatutory Exemptions\n(5a) \nIRC section \nauthority for \nexemption\n(5b) \nEnter the portion of \nColumn (3) representing \nincome exempt by \nstatute\nGeneral\nSpecific\n1.\nPartner A\n123-45-6789\n 1,000 \nUK \n%\n15\nArticle 10, \nPara. 2b\nUS source \nord div\n 1,000 \nTotal Part VIII\n 1,000 \n 1,000 \nThe partnership should obtain and retain Form W-8BEN from Partner A, in support of the requested modification.\n", "25\nModification For Foreign Partner Statutory Exemptions (Columns 5a through 5b)\nColumn (5a): IRC section authority for exemption. Enter the specific Internal Revenue Code section supporting the exemption from tax.\nColumn (5b): Enter the portion of Column (3) representing income exempt by statute. Enter the amount of the partner’s distributive share of \npartnership adjustments which are subject to the exemption indicated in column 5a.\nExample 2: Foreign Partner B has a distributive share adjustment of $1,000 interest income from Partnership ABC that is eligible for the portfolio \nexclusion under IRC Section 871 regarding interest on certain portfolio debt instruments. Partnership ABC would complete Form 8980, Part VIII, as \nfollows, to request the modification based on Partner B’s Code- based exemption:\nD \nR \nA \nF \nT \n \nC \nO \nP \nY\nN \nO \nT \n \nF \nO \nR \n \nR \nE \nL \nE \nA \nS \nE\nPage 12 of 14\nCatalog Number 37818U\nwww.irs.gov\nForm 8980 (Rev. 10-2020)\nPart VIII - Foreign Partners: Modification Pursuant to Tax Treaty Claims Under Applicable Regulations & Statutory Exemptions Other Than Section 501(a)\nA. Enter the total number of reviewed year partners included under this modification request\n(1) \nName of Partner\n(2) \nTIN of Partner \n(3) \nTotal Share of \nReallocation & Residual \nGrouping Adjustments \n(net positive \nadjustments only)\nGeneral\nSpecific\nTax Treaty Modification\n(4a) \nCountry of \nResidence\n(4b) \nTreaty \nRate\n(4c) \nTreaty \nArticle and \nParagraph\n(4d) \nType of Income \npertaining to the treaty \nbenefit identified in \ncolumn (4c)\nGeneral\nSpecific\n(4e) \nEnter the portion of column \n(3) representing Income for \nwhich the partner is claiming \ntax treaty benefits for \npayments subject to \nwithholding under Chapter 3\nGeneral\nSpecific\nStatutory Exemptions\n(5a) \nIRC section \nauthority for \nexemption\n(5b) \nEnter the portion of \nColumn (3) representing \nincome exempt by \nstatute\nGeneral\nSpecific\n1.\nPartner B\n987-65-4321\n 1,000 \n%\n871\n 1,000 \nTotal Part VIII\n 1,000 \n 1,000 \nExample 3: Foreign Partner C has a distributive share adjustment of $1,000 interest income from Partnership ABC. Partner C is an international \norganization within the meaning of §7701(a)(18) and such income is within the scope of exemption granted by §892. Partnership ABC would complete \nForm 8980, Part VIII, as follows, to request the modification based on Partner C’s foreign tax-exempt status:\nD \nR \nA \nF \nT \n \nC \nO \nP \nY\nN \nO \nT \n \nF \nO \nR \n \nR \nE \nL \nE \nA \nS \nE\nPage 17 of 19\nCatalog Number 37818U\nwww.irs.gov\nForm 8980 (Rev. 10-2020)\nPart VIII - Foreign Partners: Modification Pursuant to Tax Treaty Claims Under Applicable Regulations & Statutory Exemptions Other Than Section 501(a)\nA. Enter the total number of reviewed year partners included under this modification request\n(1) \nName of Partner\n(2) \nTIN of Partner \n(3) \nTotal Share of \nReallocation & Residual \nGrouping Adjustments \n(net positive \nadjustments only)\nGeneral\nSpecific\nTax Treaty Modification\n(4a) \nCountry of \nResidence\n(4b) \nTreaty \nRate\n(4c) \nTreaty \nArticle and \nParagraph\n(4d) \nType of Income \npertaining to the treaty \nbenefit identified in \ncolumn (4c)\nGeneral\nSpecific\n(4e) \nEnter the portion of column \n(3) representing Income for \nwhich the partner is claiming \ntax treaty benefits for \npayments subject to \nwithholding under Chapter 3\nGeneral\nSpecific\nStatutory Exemptions\n(5a) \nIRC section \nauthority for \nexemption\n(5b) \nEnter the portion of \nColumn (3) representing \nincome exempt by \nstatute\nGeneral\nSpecific\n1.\nPartner C\n12-3456789\n 1,000 \n%\n892(b)\n 1,000 \nTotal Part VIII\n 1,000 \n 1,000 \nPartnership ABC should obtain and retain Form W-8EXP from Partner C, in support of the requested modification unless other facts surrounding the \npayment reasonably indicate that the beneficial owner of the payment is an international organization.\nSupporting Documentation for Part VIII. For each relevant partner listed in Part VIII, the partnership should secure the applicable forms (listed below) \nand any other documentation supporting the facts for each relevant partner’s situation. Such supporting documents will establish that the relevant \npartner is not a U.S. person, eligibility for treaty benefits involving a reduced rate of, or exemption from, withholding as a resident of a foreign country \nwith which the United States has an income tax treaty, or establish other exempt status and applicable statutory exemptions from tax. If the partnership \nis not the withholding agent, then such forms should be obtained from the withholding agent and retained by the partnership.\nNote: All forms and supporting documentation should be retained by the partnership and should be made available to the IRS upon request. Do not \nattach such forms to Form 8980 or otherwise send such forms to the IRS. Such supporting forms to support requested modifications in Part VIII may \ninclude:\n• \nForm W-8BEN, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding and Reporting (Individuals);\n• \nForm W-8BEN-E, Certificate of Foreign Status of Beneficial Owner for United States Tax Withholding and Reporting (Entities);\n• \nForm W-8EXP, Certificate of Foreign Government or Other Foreign Organization for United States Tax Withholding and Reporting;\n• \nForm W-8IMY, Certificate of Foreign Intermediary, Foreign Flow-Through Entity, or Certain U.S. Branches for United States Tax Withholding \nand Reporting;\n• \nForm W-8ECI, Certificate of Foreign Person’s Claim That Income Is Effectively Connected With the Conduct of a Trade or Business in the \nUnited States; or\n• \nForm 8233, Exemption From Withholding on Compensation for Independent (and Certain Dependent) Personal Services of a Nonresident \nAlien Individual\nRequirement for Partner Affidavit of Unchanged Status. If a Form W-8 series form is not already on file with the partnership at the time the \nmodification is requested, or the form is no longer in effect at the time the modification is requested, the partnership should solicit the applicable form \nfrom the partner. The partner should complete the current version of the form and sign with a current date. In addition, partner must sign an “Affidavit of \nUnchanged Status” to declare the validity of the form, its applicability to the partnership’s reviewed year, and the partner’s entitlement to the reduction in \nrate or exemption from tax. Such affidavit should be attached to the completed Form W-8 series form and retained by the partnership. The following is an \nexample of an affidavit and the suggested language:\n", "26\nAttachment to Form W-8BEN\nSignature of Beneficial Owner \n(or individual authorized to sign for beneficial owner)\nPrint name of signer\nDate\nCapacity in which acting \n(if not signed by beneficial owner)\nName: Beneficial Owner [from Line One of the Form W-8 BEN] \nUnder penalties of perjury, I declare that:\n• I have examined and signed the above Form W-8BEN [or other applicable W-8 series tax form] and the information and certifications contained \ntherein remained the same and unchanged throughout ______________________ [calendar year(s)] taken into account in determining the amount of \nthe requested modification in the reviewed year, and were true, correct and complete for those years; and\n• With respect to any requested reviewed year modification based on a claim of benefits under an income tax treaty with the United States, that \n_________________________ [name of the beneficial owner] would have qualified for treaty benefits throughout ______________ [calendar year(s)] \ntaken into account in determining the amount of the requested modification in the reviewed year. \nPart IX – Other Modifications Under Applicable Regulations\nUnder applicable Regulations, a partnership may request a modification not otherwise described in other parts of the Form 8980 and instructions, and \nthe IRS will consider such request and determine whether such modification is accurate and appropriate. For each partner listed in this section:\n• \nAttach a statement that describes, in detail, the requested modification.\n• \nInclude in columns 3 through 6, the partner’s adjustment allocations that are relevant to the modification requested.\n• \nIf this section is being completed for a source partnership’s closing agreement:\no\t\nEnter the source partnership’s name and TIN in columns 1 and 2; and\no\t\nEnter all relevant adjustment allocations in columns 3 through 6 that were included in the partnership’s closing agreement.\nMake sure the relevant modification type is checked in Item B, otherwise the fields in this part will not be unlocked for completion. Once the \nrelevant box in Item B is checked, you will be able to complete this part.\nA. Total number of relevant partners included under this modification request. Enter the total number of relevant partners included under this \nmodification request. This is a required field when this type of modification is requested. When the number of partners is entered, the form will \npopulate with the appropriate number of lines needed for completion.\nColumns (1) and (2): Name of Partner & TIN of Partner. Both column 1 and column 2 are required fields for each relevant partner. List the name \nand Taxpayer Identification Number (TIN) of each direct or indirect partner for which the partnership is requesting modification under this section. Both \nColumns 1 and 2 are required fields.\nColumns (3) through (6): At least one entry in columns 3 through 6 must be entered for each partner listed.\nColumn (3): Total Share of Reallocation & Residual Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 3 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Reallocation and Residual groupings. Do not include \nadjustments to Creditable Expenditures or Credits in this column. Any amounts entered in column 3 should be consistent with the allocation information \nprovided on Form 8980, Item C for such adjustments. Allocations of net negative adjustments resulting after subgroupings within the Reallocation and \nResidual grouping should be included in column 6.\nColumn (4): Total Share of Creditable Expenditure Grouping Adjustments (net positive adjustments only). Enter in the appropriate subcolumn \nof column 4 (General or Specific – depending on which imputed underpayment the adjustments were included in), the total of each partner’s distributive \nshare of all net positive adjustments (resulting after subgrouping per the NOPPA) within the Creditable Expenditure grouping. This includes decreases \nto creditable expenditures (including decreases to Creditable Foreign Tax Expenditures (CFTEs)) which were included in the subgroupings within the \nCreditable Expenditures grouping. Any amounts entered in column 4 should be consistent with the allocation information provided on Form 8980, Item \nC for such adjustments. Allocations of any net negative adjustments resulting after subgroupings (representing net increases to creditable expenditures) \nshould be included in column 6.\nColumn (5): Total Share of Credit Grouping Adjustments (positive and negative adjustments). Enter in the appropriate subcolumn of column 5 \n(General or Specific – depending on which imputed underpayment such adjustments were included in), the total of each partner’s distributive share of \nall credit adjustments (positive and negative) which were included in the Credit Grouping per the NOPPA. Any amounts entered in column 5 should be \nconsistent with the allocation information provided on Form 8980, Item C for such adjustments.\nColumn (6): Total Share of Negative Adjustments. Include in column 6, the following amounts:\n• \nThe total of all allocations for each relevant partner which are net negative adjustments (resulting after subgrouping per the NOPPA) in the \nReallocation and Residual grouping; and\n• \nThe total of any net negative adjustments (resulting after subgrouping per the NOPPA) in the Creditable Expenditures grouping. A net negative \nadjustment in the Creditable Expenditures grouping is a net increase to Creditable Expenditures after subgrouping.\nAny amounts entered in column 6 should be consistent with the allocation information provided on Form 8980, Item C, for such adjustments.\nColumn (7): Amount of Tax Paid. Include in column 7 the amount of tax paid by the partner or on behalf of the partner relative to the requested \nmodification. Note: See “BBA Partner Payments Related to Requested Modifications” under the General Instructions for information on how partner \npayments must be identified at the time payments are made.\nColumn (8): Amount of Penalty Paid. Include in column 8 the amount of any penalty paid by the partner or on behalf of the partner relative to the \nrequested modification.\nColumn (9): Date Paid. Use the drop-down calendar to select the date of payment for the amount of tax included in column 7.\n", "27\nItem F – Signature of Partnership Representative (PR)\nThis form must be signed by the partnership representative who has the sole authority to act on behalf of the partnership. \nIf the form is being filed electronically:\n• \nSignature of individual partnership representative or designated individual: The form is e-signed by entering the 5-digit PIN in the \nsignature block. Refer to the PIN Signature section under Important Tips for Electronic Submission at the beginning of this Publication. \nThis is a required field.\n• \nName of person signing form: The name, exactly as it appears in the TCC application, must be entered in the “Name of person signing the \nform” block (ex. if your name is “John T. Smith” in the TCC application, enter the name “John T. Smith” in the name block, not “John Smith,” or \n“JT Smith,” etc.). This is a required field.\n• \nTitle & Date: Enter your title and the date the form is being signed. These are both required fields.\n• \nTelephone number: Enter a daytime telephone number\n• \nName of entity partnership representative (if applicable): If the partnership representative is an entity, enter the entity name. \nIf the form is being attached to the filing of an AAR, the form can be signed manually:\n• \nIf you are an individual partnership representative:\no\t\nSignature of individual partnership representative or designated individual: Sign within this block.\no\t\nName of person signing form: Enter the name of the person signing.\no\t\nTitle, Date, and Telephone number: Enter the signor’s title, date signed, and daytime telephone number.\n• \nIf you are a designated individual: In addition to completing the five fields mentioned above, also complete the field “Name of entity \npartnership representative”. \n" ]
f15028.pdf	1020 Form 15028 (PDF)	https://www.irs.gov/pub/irs-pdf/f15028.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
f8985.pdf	1219 Form 8985 (PDF)	https://www.irs.gov/pub/irs-pdf/f8985.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/go/reader_download. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/go/acrreader. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
f14726.pdf	1020 Form 14726 (PDF)	https://www.irs.gov/pub/irs-pdf/f14726.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
f8988.pdf	1020 Form 8988 (PDF)	https://www.irs.gov/pub/irs-pdf/f8988.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
f8983.pdf	1020 Form 8983 (PDF)	https://www.irs.gov/pub/irs-pdf/f8983.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
f8984.pdf	1020 Form 8984 (PDF)	https://www.irs.gov/pub/irs-pdf/f8984.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
f8989.pdf	1020 Form 8989 (PDF)	https://www.irs.gov/pub/irs-pdf/f8989.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/products/acrobat/readstep2.html. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/support/products/\nacrreader.html. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
f8916.pdf	1020 Form 8916 (PDF)	https://www.irs.gov/pub/irs-pdf/f8916.pdf	[ "Form 8916\n(Rev. October 2020)\nDepartment of the Treasury \nInternal Revenue Service \nReconciliation of Schedule M-3 Taxable Income With \nTax Return Taxable Income for Mixed Groups \n▶ Attach to Schedule M-3 for Forms 1120, 1120-L, or 1120-PC. \n▶ Go to www.irs.gov/Form8916 for the latest information. \nOMB No. 1545-0123\nName(s) as shown on return\nEmployer identification number\n1 \nEnter total tax reconciliation amount from the applicable line of Schedule M-3. \nSee instructions .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n1\n2 \na\nLife/non-life loss limitation amount \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2a \nb\nPhased inclusion of balance of policyholders surplus account (Form 1120-L, \npage 1, line 24) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2b\nc (1) Non-life capital loss limitation .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2c(1)\n(2) Life capital loss limitation \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2c(2) \nd\n(1) Non-life charitable deduction limitation .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2d(1) \n(2) Life charitable deduction limitation \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n2d(2) \ne\n(1) Non-life dual consolidated loss amount disallowed\n.\n.\n.\n.\n.\n.\n.\n.\n2e(1) \n(2) Life dual consolidated loss amount disallowed \n.\n.\n.\n.\n.\n.\n.\n.\n.\n2e(2) \n3 \nCombine lines 1 through 2e(2) .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n3 \n4a\n(1) 1120-PC net operating loss deduction\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4a(1) \n(2) 1120-L net operating loss deduction .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4a(2) \n(3) 1120 net operating loss deduction \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4a(3) \nb (1) Non-life dividends received deduction \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4b(1) \n(2) Life dividends received deduction \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4b(2) \nc\n(1) Non-life capital loss carryforward used .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4c(1) \n(2) Life capital loss carryforward used \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4c(2) \nd\n(1) Non-life charitable deduction carryforward used .\n.\n.\n.\n.\n.\n.\n.\n.\n4d(1) \n(2) Life charitable deduction carryforward used \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n4d(2) \n5\nAdd lines 4a(1) through 4d(2) \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n5\n6\nSubtract line 5 from line 3 \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n6\n7\nOther adjustments to reconcile to taxable income on tax return (attach schedule) .\n.\n.\n.\n.\n.\n.\n7\n8\nTotal. Combine lines 6 and 7. This amount must equal the amount reported on the “Taxable income” \nline of the consolidated Form 1120, Form 1120-L, or Form 1120-PC. See instructions\n8\nFor Paperwork Reduction Act Notice, see instructions.\nCat. No. 37727E\nForm 8916 (Rev. 10-2020)\n", "Form 8916 (Rev. 10-2020)\nPage 2 \nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nFor the latest information about developments related to Form \n8916 and its instructions, such as legislation enacted after they \nwere published, go to www.irs.gov/Form8916.\nGeneral Instructions\nPurpose of Form\nUse Form 8916 to reconcile Schedule M-3 taxable income to \ntax return taxable income for a mixed group, which is a \nconsolidated tax group which uses two or more of the following \ntax return forms: Form 1120, 1120-L, or 1120-PC. A mixed \ngroup is a consolidated tax group that (1) includes both a \ncorporation that is an insurance company, and a corporation \nthat is not an insurance company, (2) includes both a life \ninsurance company and a property and casualty insurance \ncompany, or (3) includes a life insurance company, a property \nand casualty insurance company, and a corporation that is not \nan insurance company.\nWho Must File\nForm 8916 must be filed by a mixed group consisting of filers of \nForm 1120, 1120-L, or 1120-PC that is required to file Schedule \nM-3.\nHow To File\nAttach Form 8916 to the consolidated Schedule M-3. Taxpayers \nmust summarize the taxpayer tax return taxable income \ncalculation workpapers on Form 8916 and retain those \nworkpapers. The taxable income calculation workpapers need \nnot be submitted with the Form 8916.\nSpecific Instructions\nNote: All line references to Form 1120-L, Form 1120-PC, and \nForm 1120 are to the 2020 forms. \nLine 1. Schedule M-3 tax reconciliation amount. The amount \non line 1 must equal the tax reconciliation amount from the \napplicable line of Schedule M-3. For example, this amount was \nreported on Part II, line 30, column (d), of the Schedule M-3 for \nForm 1120 (Rev. December 2019), or the 2020 Schedule M-3 for \nForm 1120-L or 1120-PC.\nLine 2a. Life/non-life loss limitation amount. Enter any life/\nnon-life loss limitation amount from the supporting workpapers. \nSee section 1503(c).\nLine 4a. Net operating loss (NOL) deduction. Enter any NOL \ndeduction from supporting statements for each entity type \n(Form 1120, 1120-L, and 1120-PC). For tax years beginning in \n2020, see section 172(a)(1) as amended by section 2303 of P.L. \n116-136 (the CARES Act). Also, see section 172(b)(1)(D) and \nRev. Proc. 2020-24 for special rules for losses arising in tax \nyears 2018, 2019, and 2020.\nFor tax years beginning after 2020, see section 172(a)(2) as \namended by section 2303 of the CARES Act. See section 172 \nfor more information, including special rules for insurance \ncompanies.\nLine 7. Other adjustments to reconcile to taxable income on \ntax return. Enter on line 7 any other adjustments necessary to \nreconcile to taxable income reported on the consolidated \nincome tax return from the supporting workpapers and attach a \nshort explanation of the adjustment.\nLine 8. Total. The amount on line 8 must equal the “Taxable \nincome” line of the applicable consolidated income tax return. \nFor example, see the 2020 Form 1120, page 1, line 30; 2020 \nForm 1120-L, page 1, line 25; or 2020 Form 1120-PC, Schedule \nA, line 37.\nPaperwork Reduction Act Notice. We ask for the information \non this form to carry out the Internal Revenue laws of the United \nStates. You are required to give us the information. We need it \nto ensure that you are complying with these laws and to allow \nus to figure and collect the right amount of tax.\nYou are not required to provide the information requested on \na form that is subject to the Paperwork Reduction Act unless \nthe form displays a valid OMB control number. Books or \nrecords relating to a form or its instructions must be retained as \nlong as their contents may become material in the \nadministration of any Internal Revenue law. Generally, tax \nreturns and return information are confidential, as required by \nsection 6103.\nThe time needed to complete and file this form will vary \ndepending on individual circumstances. The estimated burden \nfor business taxpayers filing this form is approved under OMB \ncontrol number 1545-0123.\nIf you have comments concerning the accuracy of these time \nestimates or suggestions for making this form simpler, we would \nbe happy to hear from you. See the instructions for the tax \nreturn with which this form is filed.\n" ]
f8986.pdf	1219 Form 8986 (PDF)	https://www.irs.gov/pub/irs-pdf/f8986.pdf	[ "Please wait... \n \nIf this message is not eventually replaced by the proper contents of the document, your PDF \nviewer may not be able to display this type of document. \n \nYou can upgrade to the latest version of Adobe Reader for Windows®, Mac, or Linux® by \nvisiting http://www.adobe.com/go/reader_download. \n \nFor more assistance with Adobe Reader visit http://www.adobe.com/go/acrreader. \n \nWindows is either a registered trademark or a trademark of Microsoft Corporation in the United States and/or other countries. Mac is a trademark \nof Apple Inc., registered in the United States and other countries. Linux is the registered trademark of Linus Torvalds in the U.S. and other \ncountries.\n" ]
p5420b.pdf	1020 Publ 5420-B (PDF)	https://www.irs.gov/pub/irs-pdf/p5420b.pdf	[ " \n \n \n \n \n \n \nA Step-by-Step Guide to Using the IRS \nNon-Filers: Enter Payment Info Here \nTool to Get an Economic Impact Payment \n \n \n \n \n \n \n \n \nOctober 2020 \n \n \n \n \n \n \nPublication 5420-B (Rev. 10-2020) Catalog Number 74924F \nDepartment of the Treasury Internal Revenue Service www.irs.gov \n", " \n \n2 \| O c t o b e r 2 0 2 0 \n \n \n \nEconomic Impact Payments \nSome people don’t have to file a tax return but may still be eligible for an Economic \nImpact Payment. See if you qualify, then follow the steps to register for your payment. \n \nHow much are payments worth? \nUp to $1,200 for individuals, $2,400 for married couples and $500 per qualifying child under 17. \n \nWho is eligible? \nU.S. citizens, permanent residents and qualifying resident aliens who: \n Have a valid Social Security number, \n Could not be claimed as a dependent of another taxpayer, and \n Had adjusted gross income under certain limits. \nPeople who are not required to file tax returns have income that is below the income limits. \nHowever, there are individuals who file a tax return to get a refund even if they are not required \nto file. \n \nHow do you get an Economic Impact Payment? \nMost taxpayers automatically received a payment. If you didn’t and you are not required to file a \ntax return, the Non-Filers: Enter Payment Info Here is a free IRS tool that allows you to easily \nand quickly provide information about yourself and your family. \n \nThe IRS will use this information to determine your eligibility and send you an Economic Impact \nPayment. \n \nWho should use the Non-filers tool? \nOnly people who did not already use the Non-Filers tool, and: \n had gross income at or below $12,200 ($24,400 for married couples) for 2019, \n did not file a return for 2018 or 2019, \n do not plan to file a return for 2019, \n were not otherwise required to file a federal income tax return for 2019, and \n cannot be claimed as a dependent on someone else’s tax return. \nTo determine if you are required to file a 2019 tax return or if you should file to get a refund, you \ncan use the IRS’s Interactive Tax Assistant tool – Do I Need to File a Tax Return? – and answer \nbasic questions. \n \nBefore you begin \nAnyone using the tool needs to have: \n Name, exactly as it appears on Social Security card \n A work-eligible Social Security number \n An email address to help create your account on the Non-Filers tool \n A mailing address where you can receive the payment and confirmation letter, which the \nIRS will mail within 15 days after your payment is issued \n \n", " \n \n3 \| O c t o b e r 2 0 2 0 \n \n \n \nIf you want your payment via direct deposit, you’ll need banking information – the routing and \naccount number. \n• \nIf you want to receive your payment in a U.S. affiliated bank account but don’t have one, \nvisit the FDIC website. FDIC has information on how to choose the right account and \nwhere to find a bank that can open an account online, if needed. \n• \nYou may be able to have your payment sent to your reloadable prepaid debit card. Many \nreloadable prepaid cards have account and routing numbers that you could provide to \nthe IRS through the Non-Filers: Enter Payment Info Here tool. You would need to check \nwith the financial institution to ensure your card can be re-used and to obtain the routing \nnumber and account number, which may be different from the card number. When \nproviding this information in the Non-Filers tool, you should indicate that the account and \nrouting number provided are for a checking account unless your financial institution \nindicates otherwise. \n \nIf the IRS sent you an Identity Protection Personal Identification Number (IP PIN) in the past, \nyou’ll need it to use this tool. If you lost your IP PIN, use the Get an IP PIN tool to retrieve your \nnumber. \n \nNOTE: The Non-Filers tool includes a space for your license or state ID number, if you have \none, to digitally sign your document in the Non-Filers tool. There are other ways to do this, so a \nlicense or state ID is optional in the tool. However, it may be requested by an organization that \nis helping you use the Non-Filers tool. \n \n \nLet’s begin! \n \nStart at IRS.gov. From the IRS.gov homepage, select Non-Filers: Enter Payment Info Here. \n \n \n \n \n \n", " \n \n4 \| O c t o b e r 2 0 2 0 \n \n \n \nConfirm you can use the Non-Filers tool. Carefully review the information on the screen to \nmake sure you can use the tool. Click on “Get Started” after you confirm this is the correct tool \nto use. Also, please review the system requirements under the FAQs link to the left to confirm \nyour computer will work with this tool. \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n", " \n \n5 \| O c t o b e r 2 0 2 0 \n \n \nCreate an account. Review the privacy statement. Then, to create your account, enter your \nemail address and create a user ID and password. Enter a phone number, if applicable. Please \nuse a phone number you will have access to now and in the future. If you already created an \naccount and are returning to the tool, click the “Sign In” button or the “I forgot my user ID or \npassword” link as needed. \n \n \n \nClick “Create Account” to move on. \n", " \n \n6 \| O c t o b e r 2 0 2 0 \n \n \n \nGet your account confirmation. This screen confirms you successfully created an account. \nYou will also receive an email confirmation from [email protected]. \nYou can print this page for your records. \n \n \n \n \nSelect “Continue.” You will be directed to a “Step 1” screen where you will input your information \nto register for the payment. \n \n \n \n \n \n \n \n \n \n \n", " \n \n7 \| O c t o b e r 2 0 2 0 \n \n \n \nSTEP 1 page: Register for your payment. On the top section of this page, take the \nfollowing steps: \n Select your filing status (Single or Married filing jointly). \nAlert: If you are entering information for yourself, and your spouse receives \nSocial Security, Supplemental Security Income, Railroad Retirement or Veteran’s \nbenefits, you should enter your information as a “Single” filer instead of “Married \nFiling Jointly.” \n Enter your personal information, including your Social Security number (and your \nspouse’s, if you select “Married filing jointly),” and your address. Note: Do not use the \n“Foreign Country Name” field if your address is in the U.S. \n Check the box if someone can claim you or your spouse as a dependent. \n Enter any dependents and their SSN or Adoption Tax Identification number (ATIN). If \nyou have more than four dependents, click the “Add” box to enter more. \n If the IRS has sent an Identity Protection Personal Identification Number (IP PIN) for any \nof your dependents, enter the IP PIN on the appropriate line for that dependent. \n \n \n \n", " \n \n8 \| O c t o b e r 2 0 2 0 \n \n \n \nOn the bottom two sections of this page: \n Complete your bank information if you want your payment as direct deposit (otherwise \nthe IRS will mail your payment as a check or a debit card). \n Double check your routing and account numbers for accuracy. \n Enter an Identity Protection Personal Identification Number (IP PIN) for you or your \nspouse, if applicable. \n \nThen select “Continue to Step 2” to advance to the next screen. \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n", " \n \n9 \| O c t o b e r 2 0 2 0 \n \n \n \nSTEP 2 page: Verifications and signatures: Simply follow the instructions on the page. You’ll \nneed your driver’s license (or state-issued ID) information. If you don’t have one, leave it blank. \n \nThe form asks for last year’s Adjusted Gross Income (AGI) from your tax return, or your five-\ndigit self-selected signature PIN. If you didn’t file a tax return last year, enter “0” for the AGI and \ncontinue to the next section, where you’ll digitally sign. \n \nFor the last step on this page, you’ll need to verify your email address. In your email account, \nlook for a verification email from [email protected]. In that verification \nemail, select “Update Your Account.” This will verify your email address. Then you can return to \nthe Non-Filers tool to complete filing. \n \n \n \nSelect “Continue to E-File.” \n \n", " \n \n10 \| O c t o b e r 2 0 2 0 \n \n \n \nAfter you register: You will receive an e-mail from Customer Service at Free File Fillable \nForms, a trusted IRS partner. The email will either acknowledge you have successfully \nsubmitted your information or tell you there is a problem and how to correct it. \n \nIf you are using a public computer, such as a public library computer or other shared computer, \nbe sure to sign out and completely close the Non-Filers: Enter Payment Info browser before \nleaving the computer. \n \nGetting your payment: The IRS will confirm your eligibility, then calculate and send your \nEconomic Impact Payment. \n \nChecking payment status: You can use the Get My Payment tool at IRS.gov within two weeks \nto check your payment status. Until your payment is scheduled, you will receive a “Payment \nStatus Not Available” message. \n \nTo use Get My Payment, you’ll need your Social Security number or individual tax ID number, \ndate of birth and address. \n \nAccount information is updated once per day overnight, so there's no need to check back more \nthan once per day. Checking more than five times per day will result in an account lock for 24 \nhours. \n \nIf you enter information that does not match our records three times within 24 hours, you will be \nlocked out of Get My Payment for security reasons. Do not contact the IRS for assistance for a \nlockout. The lock out will only release when the 24 hours has passed. For more information, see \nthe Get My Payment Frequently Asked Questions. \n \nResources \n• \nFrequently Asked Questions at the IRS.gov Economic Impact Payments Information Center \nfor information on eligibility, emerging issues and more. \n \n• \nFrequently Asked Questions within the Non-Filers tool itself have information about using \nthe tool. \n \n" ]
p4576.pdf	1020 Publ 4576 (PDF)	https://www.irs.gov/pub/irs-pdf/p4576.pdf	[ "Publication 4576\nMISSION\nThe mission of the Internal Revenue Service Independent \nOffice of Appeals (Appeals) is to resolve federal tax \ncontroversies without litigation on a basis which:\n\t\n Is fair and impartial to both the government and the \ntaxpayer;\n\t\n Promotes a consistent application and interpretation \nof, and voluntary compliance with, the federal tax \nlaws; and\n\t\n Enhances public confidence in the integrity and \nefficiency of the IRS.\nAppeals is separate from, and independent of, other \nfunctions within the IRS. We make decisions based on our \nown independent review of the facts and the law.\nHOW THE APPEALS PROCESS WORKS\nHere is what Appeals will do:\n\t\n Independently review the IRS’s position, the information \nor documentation you provided, and your position as \noutlined in your protest.\n\t\n Contact you to confirm receipt of your case and offer \nyou the opportunity to provide more information about \nyour case or schedule a conference to discuss your case \nbefore we make a determination.\n\t\n Note: We may refer any new information or documentation \nyou provide to the IRS’s Compliance function for their \nreview.\nHere is what you should do:\n\t\n Be fully prepared to discuss and support the facts of your \ncase, as well as your reasons for requesting penalty relief.\n\t\n Respond to us by requested or agreed-upon deadlines.\nHere is how we consider and resolve cases:\n\t\n We will apply the law to the facts of your case and \nconsider any potential hazards of litigation.\n\t\n We will consider applicable policy statements, case law, \nrevenue procedures, and revenue rulings. \n\t\n We will make the decision on how to resolve your case. \nWe will explain the basis for our decision to you.\nOrientation to the Penalty Appeals Process\n\t\n Appeals Process\n\t\n Right to Retain Representation \n\t\n Payment Options\nINTRODUCTION\nThis publication summarizes the Appeals process for penalty \nappeal cases. It also discusses several topics related to your \nappeal, including: your right to retain representation before \nAppeals, your ability to request further review of our decision \nif you do not agree, and your options for paying any amounts \ndue. It concludes with some useful resources for you to \nconsider, including our website and contact information for \nthe Taxpayer Advocate Service (TAS).\n", "YOUR RIGHT TO RETAIN REPRESENTATION\n\t\n You can contact Appeals directly and represent yourself.\n\t\n If you want to be represented by someone else, they \nmust be an attorney, a certified public accountant, or an \nenrolled agent authorized to practice before Appeals. If \nyou choose to be represented, please provide us with \na completed copy of Form 2848, Power of Attorney and \nDeclaration of Representative, for each person who is a \nparty to the appeal.\n\t\n If you cannot afford representation, please review IRS \nPublication 4134, Low Income Taxpayer Clinic List, to \nlearn about free or low-cost assistance available to \nlow-income taxpayers. In addition, low income taxpayer \nclinics provide education about taxpayer rights and \nresponsibilities for taxpayers who speak English as a \nsecond language.\nTIME FRAME FOR THE APPEALS PROCESS\n\t\n We generally work cases on a first-in, first-out basis.\n\t\n If desired, you may contact us to discuss approximately \nhow long it will take to resolve your case if no unusual \ncircumstances develop.\nTHE CLOSING PROCESS AND YOUR OPTIONS\n\t\n If you agree with our determination, no further action will \nbe required of you in most cases.\n\t\n If you do not agree with our determination, you may \nrequest further review of the penalties by filing a formal \nsuit with either the United States District Court having \njurisdiction or the United States Court of Federal Claims. \nNote: Most penalties must be paid in full before filing suit.\nYOUR PAYMENT OPTIONS\n\t\n At any time, you can make a payment that will stop \ninterest and/or penalties from continuing to accrue. \nPenalties (up to the maximum allowed by law) and \ninterest will continue to accrue on any unpaid balance \ndue until the date of payment.\nYOUR PAYMENT OPTIONS (CONT.)\n\t\n When our determination has been made, the IRS will \nissue you a notice showing the amount you owe, \nincluding interest, if applicable. You should make \narrangements to pay this amount in full as soon as \npossible. If you are not able to make full payment \nimmediately, your options include:\n\t\n Making a partial payment (interest will continue to \naccrue),\n\t\n Entering into an installment agreement (interest will \ncontinue to accrue), and\n\t\n Making an offer in compromise. \n\t\n If you wish to make any of the above payment \narrangements, please contact the IRS by calling 800-829-\n1040 for individuals and 800-829-4933 for businesses. An \nIRS Customer Service Representative will assist you.\n\t\n You can read IRS Publication 594, The IRS Collection \nProcess, for more information about payment options.\n\t\n You can also visit http://www.irs.gov/paymentplan for \nmore information on installment agreements and online \npayment agreements.\nOTHER USEFUL RESOURCES\n\t\n Visit www.irs.gov/appeals for more information about \nAppeals. At our site, you can also view videos and \npodcasts of the Appeals process.\n\t\n Call the Taxpayer Advocate Service (TAS) at \n877-777-4778 [or TTY/TTD 800–829–4059]. TAS is an \nindependent organization within the IRS that helps \ntaxpayers and protects taxpayers’ rights. TAS can offer \nyou help if your tax problem is causing a financial \ndifficulty, you’ve tried and been unable to resolve your \nissue with the IRS, or you believe an IRS system, process, \nor procedure just isn’t working as it should. If you qualify \nfor TAS assistance, which is always free, TAS will do \neverything possible to help you. To learn more about TAS, \nvisit https://taxpayeradvocate.irs.gov/.\n\t\n Call 800-TAX-FORM to order forms and publications.\nPublication 4576 (Rev. 10-2020) Catalog Number 49395S Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
i8872.pdf	1020 Inst 8872 (PDF)	https://www.irs.gov/pub/irs-pdf/i8872.pdf	[ "Instructions for Form 8872\n(Rev. October 2020)\nPolitical Organization\nReport of Contributions and Expenditures\nDepartment of the Treasury\nInternal Revenue Service\nSection references are to the Internal Revenue Code unless \notherwise noted.\nFuture Developments\nFor the latest information about developments related to \nForm 8872 and its instructions, such as legislation after they \nwere published, go to IRS.gov/Form8872.\nWhat’s New\nRequired electronic filing of Form 8872. The Taxpayer \nFirst Act amends Internal Revenue Code (IRC) section 527(j) \nto require Form 8872, Political Organization Report of \nContributions and Expenditures, to be filed electronically. \nThe electronic filing requirement is effective for periods \nbeginning after December 31, 2019. The IRS will not accept \nForm 8872 reports filed on paper for periods beginning after \nDecember 31, 2019. See Where and How To File, later.\nGeneral Instructions\nThis form and all attachments are subject to public \ninspection. Do not enter social security numbers on \nthis form or any attachments.\nPurpose of Form\nUnless an exception applies (see Who Must File below), a \ntax-exempt section 527 political organization must file Form \n8872 to report certain contributions received and \nexpenditures made. Generally, an organization that is \nrequired to file Form 8872 must also file Form 8871, Political \nOrganization Notice of Section 527 Status, within 24 hours of \nthe organization's formation or within 30 days of any material \nchange to the information reported on Form 8871.\nNote. The organization isn't required to report contributions \naccepted or expenditures made after July 1, 2000, if they \nwere received or made under a contract entered into before \nJuly 2, 2000.\nWho Must File\nEvery section 527 political organization that accepts a \ncontribution or makes an expenditure for an exempt function \nduring the calendar year must file Form 8872, except:\n• A political organization that isn't required to file Form 8871,\n• A political organization that is subject to tax on its income \nbecause it didn't file or amend a Form 8871, or\n• A qualified state or local political organization.\nA qualified state or local political organization is a political \norganization that meets the following requirements.\n• The organization's exempt functions are solely for the \npurpose of influencing or attempting to influence the \nselection, nomination, election, or appointment of any \nindividual to any state or local political office or office in a \nstate or local political organization.\nCAUTION\n!\n• The organization is subject to state law that requires it to \nreport information that is similar to that required on Form \n8872.\n• The organization files the required reports with the state.\n• The state makes such reports public and the organization \nmakes them open to public inspection in the same manner \nthat organizations must make Form 8872 available for public \ninspection.\nFor additional information, including the prohibition of \ninvolvement in the organization of a federal candidate or \noffice holder, see section 527(e)(5).\nWhen To File\nDue dates for Form 8872 vary depending on whether the \nform is due for a reporting period that occurs during an \neven-numbered or odd-numbered year.\nNote. If any due date falls on a Saturday, Sunday, or legal \nholiday, the organization may file on the next business day.\nEven-Numbered Years\nThe organization may opt to file its reports on either a \nquarterly or monthly basis, but it must file on the same basis \nfor the entire calendar year.\nQuarterly reports. File the first report for the first quarter of \nthe calendar year in which the organization accepts a \ncontribution or makes an expenditure. Quarterly reports are \ndue by the 15th day after the last day of each calendar \nquarter, except the year-end report, which is due by January \n31 of the following year. In addition, the organization may \nhave to file a pre-election report, a post-general election \nreport, or both, as explained below.\nMonthly reports. File the first report for the first month of \nthe calendar year in which the organization accepts a \ncontribution or makes an expenditure. Reports are due by the \n20th day after the end of the month. This report must reflect \nall reportable contributions accepted and expenditures made \nduring the month for which the report is being filed. No \nmonthly reports are due for October and November. Instead, \nthe organization must file a pre-general election report and a \npost-general election report (see Pre-election report and \nPost-general election report). In addition, a year-end report \nmust also be filed by January 31 of the following year instead \nof a monthly report for December.\nPre-election report. This report must be filed before any \nelection for which the organization made a contribution or \nexpenditure. This report must be filed by the:\n• 12th day before the election, or\n• 15th day before the election, if the organization is posting \nthe report by certified or registered mail.\nThis report must reflect all reportable contributions \naccepted and expenditures made through the 20th day \nbefore the election.\nPost-general election report. File by the 30th day after the \ngeneral election. This report must reflect all reportable \nOct 08, 2020\nCat. No. 30584F\n", "contributions accepted and expenditures made through the \n20th day after the general election.\n“Election” means:\n• A general, special, primary, or runoff election for a federal \noffice;\n• A convention or caucus of a political party that has \nauthority to nominate a candidate for federal office;\n• A primary election held for the selection of delegates to a \nnational nominating convention of a political party; or\n• A primary election held for the expression of a preference \nfor the nomination of individuals for election to the office of \nPresident.\n“General election” means:\n• An election for a federal office held in even-numbered \nyears on the Tuesday following the first Monday in \nNovember; or\n• An election held to fill a vacancy in a federal office (that is, \na special election) that is intended to result in the final \nselection of a single individual to the office at stake in a \ngeneral election.\nOdd-Numbered Years\nThe organization may opt to file its reports on either a \nsemiannual or monthly basis, but it must file on the same \nbasis for the entire calendar year.\nSemiannual reports. File the mid-year report by July 31 for \nthe period beginning January 1 through June 30. File the \nyear-end report by January 31 of the following year for the \nperiod beginning July 1 and ending December 31.\nMonthly reports. File the first report for the first month of \nthe calendar year in which the organization accepts a \ncontribution or makes an expenditure. Reports are due by the \n20th day after the end of the month, except for the December \nreport, which is due on January 31 of the following year. This \nreport must reflect all reportable contributions accepted and \nexpenditures made during the month for which the report is \nbeing filed.\nWhere and How To File\nForm 8872 must be filed electronically.\nFile using the IRS website at IRS.gov/polorgs. A \nusername and a password are required for electronically \nfiling Form 8872. Organizations that have completed the \nelectronic filing of Form 8871 and submitted a completed, \nsigned Form 8453-X, Political Organization Declaration for \nElectronic Filing of Notice of Section 527 Status, will receive \na username and a password in the mail. Organizations that \nhave completed the electronic filing of Form 8871, but \nhaven't received their username and password, may request \nthem by writing to the following address.\nInternal Revenue Service\nAttn: Request for Form 8872\nPassword Mail Stop 6273\nOgden, UT 84201\nIf you have forgotten or misplaced the username and \npassword issued to your organization after you filed your \ninitial Form 8871 and Form 8453-X, please send a letter \nrequesting a new username and password to the above \naddress. You may also fax your request to 801-620-3249. It \nmay take 3–6 weeks for your new username and password to \narrive, as they will be mailed to the organization. Submit your \nrequest as soon as possible after you discover the loss of \nyour username and password to allow you to submit your \nnext filing on time.\nWho Must Sign\nForm 8872 must be signed by an official authorized by the \norganization to sign this report.\nPenalty\nA penalty will be imposed if the organization is required to file \nForm 8872 and it:\n• Fails to file the form by the due date, or\n• Files the form but fails to report all of the information \nrequired or it reports incorrect information.\nThe penalty is 21% for tax years beginning after \nDecember 31, 2017 (35% for tax years beginning before \nDecember 31, 2017) of the total amount of contributions and \nexpenditures to which a failure relates.\nOther Required Reports and Returns\nAn organization that files Form 8872 may also be required to \nfile the following forms.\n• Form 990, Return of Organization Exempt From Income \nTax, or Form 990-EZ, Short Form Return of Organization \nExempt From Income Tax (or other designated annual \nreturn).\n• Form 1120-POL, U.S. Income Tax Return for Certain \nPolitical Organizations (annual return).\nPublic Inspection of Form 8872\nThe IRS will make Form 8872 (including Schedules A and B) \nopen to public inspection on the IRS website at IRS.gov/\npolorgs. In addition, the organization must make available for \npublic inspection a copy of this report during regular business \nhours at the organization's principal office and at each of its \nregional or district offices having at least 3 paid employees. A \npenalty of $20 per day will be imposed on any person under \na duty to comply with the public inspection requirement for \neach day a failure to comply continues. The maximum \npenalty imposed on all persons for failures relating to one \nreport is $10,000.\nTelephone Assistance\nIf you have questions or need help completing Form 8872, \nplease call 1-877-829-5500. This toll-free telephone service \nis available Monday through Friday.\nExempt Organizations Update\nThe IRS has established a new, subscription-based email \nservice for tax professionals and representatives of \ntax-exempt organizations. Subscribers will receive periodic \nupdates from the IRS regarding exempt organization’s tax \nlaw and regulations, available services, and other \ninformation. To subscribe, visit IRS.gov/eo.\nSpecific Instructions\nLine A\nEnter the beginning and ending date for the period to which \nthis report relates. If the organization filed a prior report for \nthe calendar year, the beginning date must be the first day \nfollowing the ending date shown on the prior report.\nLine B\n• Check the \"Initial report\" box if this is the first Form 8872 \nfiled by the organization for this period.\n-2-\n", "• Check the \"Change of address\" box if the organization \nchanged its address since it last filed Form 8871, Form 8872, \nForm 990 (or 990-EZ), or Form 1120-POL.\n• Check the \"Amended report\" box if the organization is filing \nan amended report.\n• Check the \"Final report\" box if the organization won't be \nrequired to file Form 8872 in the future.\nEmployer Identification Number (EIN)\nEnter the correct EIN in the space provided as shown on the \nForm 8871 the organization filed.\nDO NOT enter social security numbers on Form 8872 \nor on any attachments to this form.\nForeign Address\nEnter the information in the following order: city or town, state \nor province, and country. Follow the country's practice for \nentering the postal code, if any. Don't abbreviate the country \nname.\nLines 5a and 5b\nEnter the name and address of the person in possession of \nthe organization's books and records.\nLines 6a and 6b\nEnter the name and address of the person whom the public \nmay contact for more information about the organization.\nLines 8a through 8h\nCheck only one box. See When To File, earlier, for details on \nthe types of reports and the periods covered.\nLine 8f. If the organization is filing on a monthly basis, enter \nthe month for which this report is being filed. During \neven-numbered years, don't check this box to report \nOctober, November, or December activity. Instead, file a \npre-general election report, post-general election report, a \nyear-end report; and check the appropriate box on line 8d, \n8g, or 8h.\nLine 8g. If the organization is filing a pre-election report, also \nindicate the type of election (primary, general, convention, \nspecial, or runoff) on line 8g(1), the date of the election on \nline 8g(2), and the state in which the election is held on \nline 8g(3).\nLine 8h. If the organization is filing a post-general election \nreport, indicate the date of the election on line 8h(1) and the \nstate in which the election was held on line 8h(2).\nLine 9\nIf the organization is required to file Schedule(s) A, enter the \ntotal of all subtotals shown on those schedules. If the \norganization isn't required to file Schedule A, enter zero.\nLine 10\nIf the organization is required to file Schedule(s) B, enter the \ntotal of all subtotals shown on those schedules. If the \norganization isn't required to file Schedule B, enter zero.\nSchedule A—Itemized Contributions\nNote. Multiple Schedules A can be filed with any report. \nNumber each schedule in the box in the top right corner of \nthe schedule. Be sure to include both the number of the \nspecific page and the total number of Schedules A (for \nexample, \"Schedule A, page 2 of 5\").\nCAUTION\n!\nThe organization must list on Schedule A each contributor \nfrom whom it accepted contributions during the calendar year \nif:\n• The aggregate amount of the contributions accepted from \nthat person during the calendar year as of the end of this \nreporting period was at least $200, and\n• Any of those contributions were accepted during this \nreporting period.\nTreat contributions as accepted if the contributor has \ncontracted or is otherwise obligated to make the contribution.\nIn-kind contributions must be included. These \ncontributions may be identified by including “(In-kind)” in the \ncontributor's name field.\nAs an entry on the last page of Schedule A, enter the total \namount of all contributions received from contributors whose \naggregate contributions were less than $200 and aren't \nreported elsewhere. Enter “Aggregate below Threshold” \ninstead of the contributor's name. Also enter your \norganization's address and the last day of the reporting \nperiod (for example, Jan. 31); and enter “N/A” for employer, \noccupation, and date.\nName of Contributor's Employer\nIf the contributor is an individual, enter the name of the \norganization or person by whom the contributor is employed \n(and not the name of his or her supervisor). If the individual is \nself-employed, enter \"Self-employed.\" If the individual isn't \nemployed, enter “Not employed.” If the contributor isn't an \nindividual, enter “N/A.”\nContributor's Occupation\nIf the contributor is an individual, enter the principal job title or \nposition of that contributor. If the individual is self-employed, \nenter the principal job title or position of that contributor. If the \nindividual isn't employed, enter a descriptive title to explain \nthe individual's status such as “Retired,” “Student,” \n“Homemaker,” or “Unemployed.” If the contributor isn't an \nindividual, enter “N/A.”\nAggregate Year-to-Date Contributions\nEnter the total amount of contributions accepted from the \ncontributor during this calendar year as of the end of this \nreporting period.\nAmount of Contribution\nIf a contributor made more than one contribution in a \nreporting period, report each contribution separately. If the \ncontribution is an in-kind contribution, report the fair market \nvalue of the contribution.\nNon-Disclosed Amounts\nAs the last entry on Schedule A, list the aggregate amount of \ncontributions that are required to be reported on this \nschedule for which the organization doesn't disclose all of the \ninformation required under section 527(j). Enter “Withheld” as \nthe contributor's name. Enter the organization's address, the \ndate of the report, and “N/A” for occupation and employer. \nThis amount is subject to the penalty for the failure to provide \nall the information required. See Penalty for details, earlier.\nSchedule B—Itemized Expenditures\nNote. Multiple Schedules B can be filed with any report. \nNumber each schedule in the box in the top right corner of \nthe schedule. Be sure to include both the number of the \n-3-\n", "specific page and the total number of Schedules B (for \nexample, \"Schedule B, page 2 of 10\").\nThe organization must list on Schedule B each recipient to \nwhom it made expenditures during the calendar year if:\n• The aggregate amount of expenditures made to that \nperson during the calendar year as of the end of this \nreporting period was at least $500, and\n• Any of those expenditures were made during this reporting \nperiod.\nTreat expenditures as made if the organization has \ncontracted or is otherwise obligated to make the expenditure.\nIn-kind expenditures must be included. These \nexpenditures may be identified by including “(In-kind)” in the \npurpose field.\nAs an entry on the last page of Schedule B, enter the total \namount of all expenditures paid to recipients whose \naggregate receipts were less than $500 and aren't reported \nelsewhere. Enter “Aggregate below Threshold” instead of the \nrecipient's name. Also enter the organization's address and \nthe last day of the reporting period (for example, Jan. 31); \nand enter “N/A” for employer, occupation, and date.\nDo not include any independent expenditures. An \n“independent expenditure” means an expenditure by \na person for a communication expressly advocating \nthe election or defeat of a clearly identified candidate that \nisn't made with the cooperation or prior consent of, in \nconsultation with, or at the request or suggestion of, a \ncandidate or agent or authorized committee of a candidate.\nName of Recipient's Employer\nIf the recipient is an individual, enter the name of the \norganization or person by whom the recipient is employed \n(and not the name of his or her supervisor). If the individual is \nself-employed, enter \"Self-employed.\" If the individual isn't \nemployed, enter “Not employed.” If the recipient isn't an \nindividual, enter “N/A.”\nRecipient's Occupation\nIf the recipient is an individual, enter the principal job title or \nposition of that recipient. If the individual is self-employed, \nenter the principal job title or position of that recipient. If the \nindividual isn't employed, enter a descriptive title to explain \nthe individual's status such as “Volunteer.” If the recipient \nisn't an individual, enter “N/A.”\nCAUTION\n!\nAmount of Each Expenditure Reported for This \nPeriod\nReport each separate expenditure made to any person \nduring the calendar year that wasn't reported in a prior \nreporting period. If the expenditure is an in-kind expenditure, \nreport the fair market value of the expenditure.\nPurpose\nDescribe the purpose of each separate expenditure.\nNon-Disclosed Amounts\nAs the last entry on Schedule B, list the aggregate amount of \nexpenditures that are required to be reported on this \nschedule for which the organization doesn't disclose all of the \ninformation required under section 527(j). Enter “Withheld” as \nthe recipient's name and as the purpose. Enter the \norganization's address, the date of the report, and “N/A” for \noccupation and employer. This amount is subject to the \npenalty for the failure to provide all the information required. \nSee Penalty for details, earlier.\nPaperwork Reduction Act Notice. We ask for the \ninformation on this form to carry out the Internal Revenue \nlaws of the United States. You are required to give us the \ninformation. We need it to ensure that you are complying with \nthese laws and to allow us to figure and collect the right \namount of tax. You are not required to provide the \ninformation requested on a form that is subject to the \nPaperwork Reduction Act unless the form displays a valid \nOMB control number. Books or records relating to a form or \nits instructions must be retained as long as their contents \nmay become material in the administration of any Internal \nRevenue law. Generally, tax returns and return information \nare confidential, as required by section 6103. However, \ncertain returns and return information of tax exempt \norganizations and trusts are subject to public disclosure and \ninspection, as provided by section 6104. The time needed to \ncomplete and file this form will vary depending on individual \ncircumstances. The estimated burden for tax exempt \norganizations filing this form is approved under OMB control \nnumber 1545-0047 and is included in the estimates shown in \nthe instructions for their information return.\n-4-\n" ]
pcir230.pdf	0614 Publ TD CIR 230 (PDF)	https://www.irs.gov/pub/irs-pdf/pcir230.pdf	[ "Treasury Department \nRegulations Governing Practice before \nthe Internal Revenue Service \nCircular No. 230 \n(Rev. 6-2014) \nCatalog Number 16586R \nwww.irs.gov \nDepartment \nof the \nTreasury \nTitle 31 Code of Federal Regulations, \nSubtitle A, Part 10, \npublished (June 12, 2014) \nInternal \nRevenue \nService \n", "31 U.S.C. §330. Practice before the Department \n(a) Subject to section 500 of title 5, the Secretary of the Treasury may — \n(1) regulate the practice of representatives of persons before the Department of the Treasury; and \n(2) before admitting a representative to practice, require that the representative demonstrate — \n(A) good character; \n(B) good reputation; \n(C) necessary qualifications to enable the representative to provide to persons valuable service; and \n(D) competency to advise and assist persons in presenting their cases. \n(b) After notice and opportunity for a proceeding, the Secretary may suspend or disbar from practice before the \nDepartment, or censure, a representative who — \n(1) is incompetent; \n(2) is disreputable; \n(3) violates regulations prescribed under this section; or \n(4) with intent to defraud, willfully and knowingly misleads or threatens the person being represented or a \nprospective person to be represented. \nThe Secretary may impose a monetary penalty on any representative described in the preceding sentence. If the \nrepresentative was acting on behalf of an employer or any firm or other entity in connection with the conduct \ngiving rise to such penalty, the Secretary may impose a monetary penalty on such employer, firm, or entity if \nit knew, or reasonably should have known, of such conduct. Such penalty shall not exceed the gross income \nderived (or to be derived) from the conduct giving rise to the penalty and may be in addition to, or in lieu of, any \nsuspension, disbarment, or censure of the representative. \n(c) After notice and opportunity for a hearing to any appraiser, the Secretary may — \n(1) provide that appraisals by such appraiser shall not have any probative effect in any administrative \nproceeding before the Department of the Treasury or the Internal Revenue Service, and \n(2) bar such appraiser from presenting evidence or testimony in any such proceeding. \n(d) Nothing in this section or in any other provision of law shall be construed to limit the authority of the \nSecretary of the Treasury to impose standards applicable to the rendering of written advice with respect to any \nentity, transaction plan or arrangement, or other plan or arrangement, which is of a type which the Secretary \ndetermines as having a potential for tax avoidance or evasion. \n(Pub. L. 97–258, Sept. 13, 1982, 96 Stat. 884; Pub. L. 98–369, div. A, title I, §156(a), July 18, 1984, 98 Stat. \n695; Pub. L. 99–514, §2, Oct. 22, 1986, 100 Stat. 2095; Pub. L. 108–357, title VIII, §822(a)(1), (b), Oct. 22, 2004, \n118 Stat. 1586, 1587; Pub. L. 109–280, title XII, §1219(d), Aug. 17, 2006, 120 Stat. 1085.) \nPage 2 \nTreasury Department Circular No. 230\n", " \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \nTable of Contents \nParagraph 1. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 \n§ 10.0 Scope of part. \n. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 \nSubpart A — Rules Governing Authority to Practice . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 \n 10.1 Offices. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 \n§\n 10.2 Definitions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 \n§\n§ 10.3 Who may practice. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 \n§ 10.4 Eligibility to become an enrolled agent, enrolled retirement plan agent, or \nregistered tax return preparer. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 \n§ 10.5 Application to become an enrolled agent, enrolled retirement plan agent, or \nregistered tax return preparer. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 \n§ 10.6 Term and renewal of status as an enrolled agent, enrolled retirement plan agent, or \nregistered tax return preparer. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 \n§ 10.7 Representing oneself; participating in rulemaking; limited practice; and special appearances. . . 16 \n§ 10.8 Return preparation and application of rules to other individuals. . . . . . . . . . . . . . . . . . . . . . . . . . . 17 \n§ 10.9 Continuing education providers and continuing education programs. . . . . . . . . . . . . . . . . . . . . . . . 17 \nSubpart B — Duties and Restrictions Relating to Practice Before the Internal Revenue Service . . . . . . . 19 \n 10.20 Information to be furnished. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 \n§\n§ 10.21 Knowledge of client’s omission. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 \n§ 10.22 Diligence as to accuracy.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19 \n§ 10.23 Prompt disposition of pending matters. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 \n§ 10.24 Assistance from or to disbarred or suspended persons and former \nInternal Revenue Service employees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 \n§ 10.25 Practice by former government employees, their partners and their associates. . . . . . . . . . . . . . . 20 \n 10.26 Notaries. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 \n§\n 10.27 Fees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 \n§\n 10.28 Return of client’s records. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 \n§\n§ 10.29 Conflicting interests. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 \n 10.30 Solicitation. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23 \n§\n§ 10.31 Negotiation of taxpayer checks. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 \n 10.32 Practice of law. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 \n§\n§ 10.33 Best practices for tax advisors. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24 \n§ 10.34 Standards with respect to tax returns and documents, affidavits and other papers. . . . . . . . . . . 24 \n§ 10.35 Competence. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25 \n§ 10.36 Procedures to ensure compliance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 \n§ 10.37 Requirements for written advice. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 \n§ 10.38 Establishment of advisory committees.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 \nTreasury Department Circular No. 230\nPage 3 \n", " \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \n \nSubpart C — Sanctions for Violation of the Regulations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 \n 10.50 Sanctions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 \n§\n§ 10.51 Incompetence and disreputable conduct. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 \n§ 10.52 Violations subject to sanction. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 \n§ 10.53 Receipt of information concerning practitioner. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 30 \nSubpart D — Rules Applicable to Disciplinary Proceedings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 \n§ 10.60 Institution of proceeding. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 \n 10.61 Conferences.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 \n§ 10.63 Service of complaint; service of other papers; service of evidence in support of complaint; \n§\n§ 10.62 Contents of complaint. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 \nfiling of papers. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32 \n§ 10.64 Answer; default. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 \n§ 10.65 Supplemental charges. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 33 \n§ 10.66 Reply to answer. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 \n§ 10.67 Proof; variance; amendment of pleadings.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 \n§ 10.68 Motions and requests. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 \n§ 10.69 Representation; ex parte communication. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 34 \n§ 10.70 Administrative Law Judge. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 \n§ 10.71 Discovery. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35 \n§ 10.72 Hearings. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 36 \n 10.73 Evidence. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38 \n§\n§ 10.74 Transcript. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 \n§ 10.75 Proposed findings and conclusions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 \n§ 10.76 Decision of Administrative Law Judge. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39 \n§ 10.77 Appeal of decision of Administrative Law Judge. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 \n 10.78 Decision on review. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 \n§\n§ 10.79 Effect of disbarment, suspension, or censure. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40 \n§ 10.80 Notice of disbarment, suspension, censure, or disqualification. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 \n 10.81 Petition for reinstatement. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 \n§\n§ 10.82 Expedited suspension.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41 \nSubpart E — General Provisions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 \n 10.90 Records. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43 \n§\n§ 10.91 Saving provision. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 \n§ 10.92 Special orders. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 \n§ 10.93 Effective date. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 \nPage 4 \nTreasury Department Circular No. 230\n", " \n \n \n \n \n \n \n \nParagraph 1. The authority citation for 31 CFR, part \n10 continues to read as follows: \nAuthority: Sec. 3, 23 Stat. 258, secs. 2-12, 60 Stat. \n237 et. seq.; 5 U.S.C. 301, 500, 551-559; 31 U.S.C. \n321; 31 U.S.C. 330; Reorg. Plan No. 26 of 1950, 15 \nFR 4935, 64 Stat. 1280, 3 CFR, 1949-1953 Comp., \np. 1017. \n§ 10.0 Scope of part. \n(a) This part contains rules governing the \nrecognition of attorneys, certified public accountants, \nenrolled agents, enrolled retirement plan agents, \nregistered tax return preparers, and other persons \nrepresenting taxpayers before the Internal Revenue \nService. Subpart A of this part sets forth rules relating \nto the authority to practice before the Internal Revenue \nService; subpart B of this part prescribes the duties \nand restrictions relating to such practice; subpart C \nof this part prescribes the sanctions for violating the \nregulations; subpart D of this part contains the rules \napplicable to disciplinary proceedings; and subpart E \nof this part contains general provisions relating to the \navailability of official records. \n(b) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \nSubpart A — Rules Governing Authority to \nPractice \n§ 10.1 Offices. \n(a) Establishment of office(s). The Commissioner \nshall \nestablish \nthe \nOffice \nof \nProfessional \nResponsibility and any other office(s) within the \nInternal Revenue Service necessary to administer \nand enforce this part. \nThe Commissioner shall \nappoint the Director of the Office of Professional \nResponsibility and any other Internal Revenue \nofficial(s) to manage and direct any office(s) \nestablished to administer or enforce this part. \nOffices established under this part include, but are \nnot limited to: \n(1) The Office of Professional Responsibility, which \nshall generally have responsibility for matters related \nto practitioner conduct and shall have exclusive \nresponsibility for discipline, including disciplinary \nproceedings and sanctions; and \n(2) An office with responsibility for matters related \nto authority to practice before the Internal Revenue \nService, including acting on applications for \nenrollment to practice before the Internal Revenue \nService and administering competency testing and \ncontinuing education. \n(b) Officers and employees within any office \nestablished under this part may perform acts necessary \nor appropriate to carry out the responsibilities of their \noffice(s) under this part or as otherwise prescribed by \nthe Commissioner. \n(c) Acting. \n The Commissioner will designate an \nofficer or employee of the Internal Revenue Service \nto perform the duties of an individual appointed \nunder paragraph (a) of this section in the absence of \nthat officer or employee or during a vacancy in that \noffice. \n(d) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011, except that \nparagraph (a)(1) is applicable beginning June 12, \n2014. \nTreasury Department Circular No. 230\n§ 10.1 — Page 5 \nTable of Contents\n", " \n \n \n§ 10.2 Definitions. \n(a) As used in this part, except where the text \nprovides otherwise — \n(1) Attorney means any person who is a member \nin good standing of the bar of the highest court of \nany state, territory, or possession of the United \nStates, including a Commonwealth, or the District of \nColumbia. \n(2) Certified public accountant \n means any person \nwho is duly qualified to practice as a certified public \naccountant in any state, territory, or possession of the \nUnited States, including a Commonwealth, or the \nDistrict of Columbia. \n(3) Commissioner refers to the Commissioner of \nInternal Revenue. \n(4) Practice before the Internal Revenue \nService comprehends all matters connected with a \npresentation to the Internal Revenue Service or any \nof its officers or employees relating to a taxpayer’s \nrights, privileges, or liabilities under laws or \nregulations administered by the Internal Revenue \nService. Such presentations include, but are not \nlimited to, preparing documents; filing documents; \ncorresponding and communicating with the Internal \nRevenue Service; rendering written advice with \nrespect to any entity, transaction, plan or arrangement, \nor other plan or arrangement having a potential for \ntax avoidance or evasion; and representing a client at \nconferences, hearings, and meetings. \n(5) Practitioner means any individual described \nin paragraphs (a), (b), (c), (d), (e), or (f) of §10.3. \n(6) A \n tax return includes an amended tax return \nand a claim for refund. \n(7) Service means the Internal Revenue Service. \n(8) Tax return preparer means any individual \nwithin the meaning of section 7701(a)(36) and 26 \nCFR 301.7701-15. \n(b) Effective/applicability date. This section is \napplicable on August 2, 2011. \n§ 10.3 Who may practice. \n(a) Attorneys. Any attorney who is not currently \nunder suspension or disbarment from practice \nPage 6 — § 10.2 \nbefore the Internal Revenue Service may practice \nbefore the Internal Revenue Service by filing with \nthe Internal Revenue Service a written declaration \nthat the attorney is currently qualified as an attorney \nand is authorized to represent the party or parties. \nNotwithstanding the preceding sentence, attorneys \nwho are not currently under suspension or disbarment \nfrom practice before the Internal Revenue Service \nare not required to file a written declaration with the \nIRS before rendering written advice covered under \n§10.37, but their rendering of this advice is practice \nbefore the Internal Revenue Service. \n(b) Certified public accountants. Any certified \npublic accountant who is not currently under \nsuspension or disbarment from practice before the \nInternal Revenue Service may practice before the \nInternal Revenue Service by filing with the Internal \nRevenue Service a written declaration that the \ncertified public accountant is currently qualified as \na certified public accountant and is authorized to \nrepresent the party or parties. Notwithstanding the \npreceding sentence, certified public accountants who \nare not currently under suspension or disbarment \nfrom practice before the Internal Revenue Service \nare not required to file a written declaration with the \nIRS before rendering written advice covered under \n§10.37, but their rendering of this advice is practice \nbefore the Internal Revenue Service. \n(c) Enrolled agents. Any individual enrolled as an \nagent pursuant to this part who is not currently under \nsuspension or disbarment from practice before the \nInternal Revenue Service may practice before the \nInternal Revenue Service. \n(d) Enrolled actuaries. \n(1) Any individual who is enrolled as an actuary \nby the Joint Board for the Enrollment of Actuaries \npursuant to 29 U.S.C. 1242 who is not currently \nunder suspension or disbarment from practice before \nthe Internal Revenue Service may practice before the \nInternal Revenue Service by filing with the Internal \nRevenue Service a written declaration stating that he \nor she is currently qualified as an enrolled actuary \nand is authorized to represent the party or parties on \nwhose behalf he or she acts. \n(2) Practice as an enrolled actuary is limited \nTreasury Department Circular No. 230\nTable of Contents\n", " \nto representation with respect to issues involving \nthe following statutory provisions in title 26 of \nthe United States Code: sections 401 (relating to \nqualification of employee \n plans), 403(a) (relating \nto whether an annuity plan meets the requirements \nof section 404(a) (2)), 404 (relating to deductibility \nof employer contributions), 405 (relating to \nqualification of bond purchase plans), 412 (relating \nto funding requirements for certain employee \nplans), 413 (relating to application of qualification \nrequirements to collectively bargained plans and \nto plans maintained by more than one employer), \n414 (relating to definitions and special rules with \nrespect to the employee plan area), 419 (relating \nto treatment of funded welfare benefits), 419A \n \n(relating to qualified asset accounts), 420 (relating \nto transfers of excess pension assets to retiree health \naccounts), 4971 (relating to excise taxes payable as \na result of an accumulated funding deficiency under \nsection 412), 4972 (relating to tax on nondeductible \ncontributions to qualified employer plans), 4976 \n(relating to taxes with respect to funded welfare \nbenefit plans), 4980 (relating to tax on reversion of \nqualified plan assets to employer), 6057 (relating \nto annual registration of plans), 6058 (relating to \ninformation required in connection with certain plans \nof deferred compensation), 6059 (relating to periodic \nreport of actuary), 6652(e) (relating to the failure \nto file annual registration and other notifications \nby pension plan), 6652(f) (relating to the failure to \nfile information required in connection with certain \nplans of deferred compensation), 6692 (relating to \nthe failure to file actuarial report), 7805(b) (relating \nto the extent to which an Internal Revenue Service \nruling or determination letter coming under the \nstatutory provisions listed here will be applied without \nretroactive effect); and 29 U.S.C. § 1083 (relating to \nthe waiver of funding for nonqualified plans). \n \n(3) An individual who practices before the \nInternal Revenue Service pursuant to paragraph (d) \n(1) of this section is subject to the provisions of this \npart in the same manner as attorneys, certified public \naccountants, enrolled agents, enrolled retirement \nplan agents, and registered tax return preparers. \n(e) Enrolled retirement plan agents — \nTreasury Department Circular No. 230\n(1) Any individual enrolled as a retirement plan \nagent pursuant to this part who is not currently under \nsuspension or disbarment from practice before the \nInternal Revenue Service may practice before the \nInternal Revenue Service. \n(2) Practice as an enrolled retirement plan agent \nis limited to representation with respect to issues \ninvolving the following programs: Employee Plans \nDetermination Letter program; Employee Plans \nCompliance Resolution System; and Employee \nPlans Master and Prototype and Volume Submitter \nprogram. In addition, enrolled retirement plan agents \nare generally permitted to represent taxpayers with \nrespect to IRS forms under the 5300 and 5500 series \nwhich are filed by retirement plans and plan sponsors, \nbut not with respect to actuarial forms or schedules. \n(3) An individual who practices before the \nInternal Revenue Service pursuant to paragraph (e) \n(1) of this section is subject to the provisions of this \npart in the same manner as attorneys, certified public \naccountants, enrolled agents, enrolled actuaries, and \nregistered tax return preparers. \n(f) Registered tax return preparers. \n(1) Any individual who is designated as a \nregistered tax return preparer pursuant to §10.4(c) \nof this part who is not currently under suspension \nor disbarment from practice before the Internal \nRevenue Service may practice before the Internal \nRevenue Service. \n(2) Practice as a registered tax return preparer \nis limited to preparing and signing tax returns \nand claims for refund, and other documents for \nsubmission to the Internal Revenue Service. A \n \nregistered tax return preparer may prepare all or \nsubstantially all of a tax return or claim for refund of \ntax. The Internal Revenue Service will prescribe by \nforms, instructions, or other appropriate guidance the \ntax returns and claims for refund that a registered tax \nreturn preparer may prepare and sign. \n(3) A registered tax return preparer may represent \ntaxpayers before revenue agents, customer service \nrepresentatives, or similar officers and employees of \nthe Internal Revenue Service (including the Taxpayer \nAdvocate Service) during an examination if the \nregistered tax return preparer signed the tax return \n§ 10.3 — Page 7 \nTable of Contents\n", " \n \n \n \nor claim for refund for the taxable year or period \nunder examination. Unless otherwise prescribed by \nregulation or notice, this right does not permit such \nindividual to represent the taxpayer, regardless of \nthe circumstances requiring representation, before \nappeals officers, revenue officers, Counsel or similar \nofficers or employees of the Internal Revenue \nService or the Treasury Department. A \n registered tax \nreturn preparer’s authorization to practice under this \npart also does not include the authority to provide \ntax advice to a client or another person except as \nnecessary to prepare a tax return, claim for refund, \nor other document intended to be submitted to the \nInternal Revenue Service. \n(4) An individual who practices before the \nInternal Revenue Service pursuant to paragraph (f) \n(1) of this section is subject to the provisions of this \npart in the same manner as attorneys, certified public \naccountants, enrolled agents, enrolled retirement \nplan agents, and enrolled actuaries. \n(g) Others. Any individual qualifying under \nparagraph §10.5(e) or §10.7 is eligible to practice \nbefore the Internal Revenue Service to the extent \nprovided in those sections. \n(h) Government officers and employees, and \nothers. An individual, who is an officer or employee \nof the executive, legislative, or judicial branch of the \nUnited States Government; an officer or employee \nof the District of Columbia; a Member of Congress; \nor a Resident Commissioner may not practice before \nthe Internal Revenue Service if such practice violates \n18 U.S.C. §§ 203 or 205. \n(i) State officers and employees. \n No officer or \nemployee of any State, or subdivision of any State, \nwhose duties require him or her to pass upon, \ninvestigate, or deal with tax matters for such State \nor subdivision, may practice before the Internal \nRevenue Service, if such employment may disclose \nfacts or information applicable to Federal tax matters. \n(j) Effective/applicability date. Paragraphs (a), (b), \nand (g) of this section are applicable beginning June \n12, 2014. Paragraphs (c) through (f), (h), and (i) of \nthis section are applicable beginning August 2, 2011. \nPage 8 — § 10.3 \n§ 10.4 Eligibility to become an enrolled agent, \nenrolled retirement plan agent, or registered tax \nreturn preparer. \n(a) Enrollment as an enrolled agent upon \nexamination. The Commissioner, or delegate, will \ngrant enrollment as an enrolled agent to an applicant \neighteen years of age or older who demonstrates \nspecial competence in tax matters by written \nexamination administered by, or administered under \nthe oversight of, the Internal Revenue Service, who \npossesses a current or otherwise valid preparer tax \nidentification number or other prescribed identifying \nnumber, and who has not engaged in any conduct \nthat would justify the suspension or disbarment of \nany practitioner under the provisions of this part. \n(b) Enrollment as a retirement plan agent upon \nexamination. The Commissioner, or delegate, will \ngrant enrollment as an enrolled retirement plan \nagent to an applicant eighteen years of age or older \nwho demonstrates special competence in qualified \nretirement plan matters by written examination \nadministered by, or administered under the oversight \nof, the Internal Revenue Service, who possesses a \ncurrent or otherwise valid preparer tax identification \nnumber or other prescribed identifying number, and \nwho has not engaged in any conduct that would justify \nthe suspension or disbarment of any practitioner \nunder the provisions of this part. \n(c) Designation as a registered tax return preparer. \nThe Commissioner, or delegate, may designate \nan individual eighteen years of age or older as \na registered tax return preparer provided an \napplicant demonstrates competence in Federal tax \nreturn preparation matters by written examination \nadministered by, or administered under the oversight \nof, the Internal Revenue Service, or otherwise meets \nthe requisite standards prescribed by the Internal \nRevenue Service, possesses a current or otherwise valid \npreparer tax identification number or other prescribed \nidentifying number, and has not engaged in any conduct \nthat would justify the suspension or disbarment of any \npractitioner under the provisions of this part. \n(d) Enrollment of former Internal Revenue Service \nemployees. The Commissioner, or delegate, may \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \ngrant enrollment as an enrolled agent or enrolled \nretirement plan agent to an applicant who, by virtue \nof past service and technical experience in the \nInternal Revenue Service, has qualified for such \nenrollment and who has not engaged in any conduct \nthat would justify the suspension or disbarment of \nany practitioner under the provisions of this part, \nunder the following circumstances: \n(1) The former employee applies for enrollment \non an Internal Revenue Service form and supplies \nthe information requested on the form and such other \ninformation regarding the experience and training of \nthe applicant as may be relevant. \n(2) The appropriate office of the Internal Revenue \nService provides a detailed report of the nature and \nrating of the applicant’s work while employed by \nthe Internal Revenue Service and a recommendation \nwhether such employment qualifies the applicant \ntechnically or otherwise for the desired authorization. \n(3) Enrollment as an enrolled agent based on an \napplicant’s former employment with the Internal \nRevenue Service may be of unlimited scope or it \nmay be limited to permit the presentation of matters \nonly of the particular specialty or only before the \nparticular unit or division of the Internal Revenue \nService for which the applicant’s former employment \nhas qualified the applicant. Enrollment as an enrolled \nretirement plan agent based on an applicant’s former \nemployment with the Internal Revenue Service will \nbe limited to permit the presentation of matters only \nwith respect to qualified retirement plan matters. \n(4) Application for enrollment as an enrolled \nagent or enrolled retirement plan agent based on an \napplicant’s former employment with the Internal \nRevenue Service must be made within three years \nfrom the date of separation from such employment. \n(5) An applicant for enrollment as an enrolled \nagent who is requesting such enrollment based \non former employment with the Internal Revenue \nService must have had a minimum of five years \ncontinuous employment with the Internal Revenue \nService during which the applicant must have been \nregularly engaged in applying and interpreting \nthe provisions of the Internal Revenue Code and \nthe regulations relating to income, estate, gift, \nTreasury Department Circular No. 230\nemployment, or excise taxes. \n(6) An applicant for enrollment as an enrolled \nretirement plan agent who is requesting such \nenrollment based on former employment with the \nInternal Revenue Service must have had a minimum \nof five years continuous employment with the \nInternal Revenue Service during which the applicant \nmust have been regularly engaged in applying and \ninterpreting the provisions of the Internal Revenue \nCode and the regulations relating to qualified \nretirement plan matters. \n(7) For the purposes of paragraphs (d)(5) and (6) \nof this section, an aggregate of 10 or more years of \nemployment in positions involving the application \nand interpretation of the provisions of the Internal \nRevenue Code, at least three of which occurred within \nthe five years preceding the date of application, is the \nequivalent of five years continuous employment. \n(e) Natural persons. Enrollment to practice may be \ngranted only to natural persons. \n(f) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.5 Application to become an enrolled agent, \nenrolled retirement plan agent, or registered tax \nreturn preparer. \n(a) Form; address. An applicant to become an \nenrolled agent, enrolled retirement plan agent, \nor registered tax return preparer must apply as \nrequired by forms or procedures established and \npublished by the Internal Revenue Service, including \nproper execution of required forms under oath or \naffirmation. The address on the application will be \nthe address under which a successful applicant is \nenrolled or registered and is the address to which all \ncorrespondence concerning enrollment or registration \nwill be sent. \n(b) Fee. A \n reasonable nonrefundable fee may be \ncharged for each application to become an enrolled \nagent, enrolled retirement plan agent, or registered \ntax return preparer. See 26 CFR part 300. \n(c) Additional information; examination. The Internal \nRevenue Service may require the applicant, as a \ncondition to consideration of an application, to file \n§ 10.5 — Page 9 \nTable of Contents\n", " \n \n \n \n \n \n \nadditional information and to submit to any written \nor oral examination under oath or otherwise. Upon \nthe applicant’s written request, the Internal Revenue \nService will afford the applicant the opportunity to \nbe heard with respect to the application. \n(d) Compliance and suitability checks. \n(1) As a condition to consideration of an \napplication, the Internal Revenue Service may \nconduct a Federal tax compliance check and \nsuitability check. The tax compliance check will be \nlimited to an inquiry regarding whether an applicant \nhas filed all required individual or business tax \nreturns and whether the applicant has failed to pay, or \nmake proper arrangements with the Internal Revenue \nService for payment of, any Federal tax debts. \nThe suitability check will be limited to an inquiry \nregarding whether an applicant has engaged in any \nconduct that would justify suspension or disbarment \nof any practitioner under the provisions of this part \non the date the application is submitted, including \nwhether the applicant has engaged in disreputable \nconduct as defined in §10.51. The application will \nbe denied only if the results of the compliance or \nsuitability check are sufficient to establish that the \npractitioner engaged in conduct subject to sanctions \nunder §§10.51 and 10.52. \n(2) If the applicant does not pass the tax \ncompliance or suitability check, the applicant will \nnot be issued an enrollment or registration card or \ncertificate pursuant to §10.6(b) of this part. An \napplicant who is initially denied enrollment or \nregistration for failure to pass a tax compliance \ncheck may reapply after the initial denial if the \napplicant becomes current with respect to the \napplicant’s tax liabilities. \n(e) Temporary recognition. On receipt of a properly \nexecuted application, the Commissioner, or delegate, \nmay grant the applicant temporary recognition to \npractice pending a determination as to whether status \nas an enrolled agent, enrolled retirement plan agent, \nor registered tax return preparer should be granted. \n \nTemporary recognition will be granted only in \nunusual circumstances and it will not be granted, in \nany circumstance, if the application is not regular on \nits face, if the information stated in the application, \nPage 10 — § 10.5 \nif true, is not sufficient to warrant granting the \napplication to practice, or the Commissioner, \nor delegate, has information indicating that the \nstatements in the application are untrue or that the \napplicant would not otherwise qualify to become \nan enrolled agent, enrolled retirement plan agent, or \nregistered tax return preparer. Issuance of temporary \nrecognition does not constitute either a designation \nor a finding of eligibility as an enrolled agent, \nenrolled retirement plan agent, or registered tax \nreturn preparer, and the temporary recognition may \nbe withdrawn at any time. \n(f) Protest of application denial. The applicant \nwill be informed in writing as to the reason(s) for \nany denial of an application. The applicant may, \nwithin 30 days after receipt of the notice of denial of \nthe application, file a written protest of the denial as \nprescribed by the Internal Revenue Service in forms, \nguidance, or other appropriate guidance. A protest \nunder this section is not governed by subpart D of \nthis part. \n(f) Effective/applicability date. \n This section is \napplicable to applications received on or after \nAugust 2, 2011. \n§ 10.6 Term and renewal of status as an enrolled \nagent, enrolled retirement plan agent, or \nregistered tax return preparer. \n(a) Term. Each individual authorized to practice \nbefore the Internal Revenue Service as an enrolled \nagent, enrolled retirement plan agent, or registered \ntax return preparer will be accorded active enrollment \nor registration status subject to renewal of enrollment \nor registration as provided in this part. \n(b) Enrollment or registration card or certificate. \nThe Internal Revenue Service will issue an \nenrollment or registration card or certificate to each \nindividual whose application to practice before the \nInternal Revenue Service is approved. Each card \nor certificate will be valid for the period stated on \nthe card or certificate. An enrolled agent, enrolled \nretirement plan agent, or registered tax return preparer \nmay not practice before the Internal Revenue Service \nif the card or certificate is not current or otherwise \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n \n \nvalid. The card or certificate is in addition to any \nnotification that may be provided to each individual \nwho obtains a preparer tax identification number. \n(c) Change of address. An enrolled agent, enrolled \nretirement plan agent, or registered tax return preparer \nmust send notification of any change of address \nto the address specified by the Internal Revenue \nService within 60 days of the change of address. \nThis notification must include the enrolled agent’s, \nenrolled retirement plan agent’s, or registered tax \nreturn preparer’s name, prior address, new address, \ntax identification number(s) (including preparer tax \nidentification number), and the date the change of \naddress is effective. Unless this notification is sent, \nthe address for purposes of any correspondence \nfrom the appropriate Internal Revenue Service \noffice responsible for administering this part shall \nbe the address reflected on the practitioner’s most \nrecent application for enrollment or registration, or \napplication for renewal of enrollment or registration. \nA practitioner’s change of address notification \nunder this part will not constitute a change of the \npractitioner’s last known address for purposes of \nsection 6212 of the Internal Revenue Code and \nregulations thereunder. \n(d) Renewal. \n(1) In general. Enrolled agents, enrolled \nretirement plan agents, and registered tax return \npreparers must renew their status with the Internal \nRevenue Service to maintain eligibility to practice \nbefore the Internal Revenue Service. Failure to \nreceive notification from the Internal Revenue \nService of the renewal requirement will not be \njustification for the individual’s failure to satisfy this \nrequirement. \n(2) Renewal period for enrolled agents. \n \n(i) All enrolled agents must renew their preparer \ntax identification number as prescribed by forms, \ninstructions, or other appropriate guidance. \n(ii) Enrolled agents who have a social security \nnumber or tax identification number that ends with \nthe numbers 0, 1, 2, or 3, except for those individuals \nwho received their initial enrollment after November \n1, 2003, must apply for renewal between November \n1, 2003, and January 31, 2004. The renewal will be \nTreasury Department Circular No. 230\neffective April 1, 2004. \n(iii) Enrolled agents who have a social security \nnumber or tax identification number that ends with \nthe numbers 4, 5, or 6, except for those individuals \nwho received their initial enrollment after November \n1, 2004, must apply for renewal between November \n1, 2004, and January 31, 2005. The renewal will be \neffective April 1, 2005. \n(iv) Enrolled agents who have a social security \nnumber or tax identification number that ends with \nthe numbers 7, 8, or 9, except for those individuals \nwho received their initial enrollment after November \n1, 2005, must apply for renewal between November \n1, 2005, and January 31, 2006. The renewal will be \neffective April 1, 2006. \n(v) Thereafter, applications for renewal as an \nenrolled agent will be required between November \n1 and January 31 of every subsequent third year as \nspecified in paragraph (d)(2)(i), (d)(2)(ii), or (d) \n(2)(iii) of this section according to the last number \nof the individual’s social security number or tax \nidentification number. Those individuals who \nreceive initial enrollment as an enrolled agent after \nNovember 1 and before April 2 of the applicable \nrenewal period will not be required to renew their \nenrollment before the first full renewal period \nfollowing the receipt of their initial enrollment. \n(3) Renewal period for enrolled retirement plan \nagents. \n(i) All enrolled retirement plan agents must \nrenew their preparer tax identification number as \nprescribed by the Internal Revenue Service in forms, \ninstructions, or other appropriate guidance. \n(ii) Enrolled retirement plan agents will be \nrequired to renew their status as enrolled retirement \nplan agents between April 1 and June 30 of every \nthird year subsequent to their initial enrollment. \n(4) Renewal period for registered tax return \npreparers. Registered tax return preparers must \nrenew their preparer tax identification number and \ntheir status as a registered tax return preparer as \nprescribed by the Internal Revenue Service in forms, \ninstructions, or other appropriate guidance. \n(5) Notification of renewal. After review and \napproval, the Internal Revenue Service will notify \n§ 10.6 — Page 11 \nTable of Contents\n", " (B) Ethics. An individual who receives \ninitial enrollment during an enrollment cycle must \ncomplete two hours of ethics or professional conduct \nfor each enrollment year during the enrollment cycle. \nEnrollment for any part of an enrollment year is \nconsidered enrollment for the entire year. \n (A) Be a qualifying continuing education \nprogram \ndesigned \nto \nenhance \nprofessional \nknowledge in Federal taxation or Federal tax related \nmatters (programs comprised of current subject \nmatter in Federal taxation or Federal tax related \nmatters, including accounting, tax return preparation \nsoftware, taxation, or ethics); and \n (B) Be a qualifying continuing education \nprogram consistent with the Internal Revenue Code \nand effective tax administration. \n \nthe individual of the renewal and will issue the \nindividual a card or certificate evidencing current \nstatus as an enrolled agent, enrolled retirement plan \nagent, or registered tax return preparer. \n(6) Fee. A reasonable nonrefundable fee may be \ncharged for each application for renewal filed. See 26 \nCFR part 300. \n(7) Forms. Forms required for renewal may be \nobtained by sending a written request to the address \nspecified by the Internal Revenue Service or from \nsuch other source as the Internal Revenue Service \nwill publish in the Internal Revenue Bulletin (see \n26 CFR 601.601(d)(2)(ii)(b)) and on the Internal \nRevenue Service webpage (www.irs.gov). \n(e) Condition for renewal: continuing education. \nIn order to qualify for renewal as an enrolled agent, \nenrolled retirement plan agent, or registered tax \nreturn preparer, an individual must certify, in the \nmanner prescribed by the Internal Revenue Service, \nthat the individual has satisfied the requisite number \nof continuing education hours. \n(1) Definitions. For purposes of this section — \n(i) Enrollment year means January 1 to \nDecember 31 of each year of an enrollment cycle. \n(ii) Enrollment cycle \n means the three successive \nenrollment years preceding the effective date of \nrenewal. \n(iii) Registration year means each 12-month \nperiod the registered tax return preparer is authorized \nto practice before the Internal Revenue Service. \n(iv) The effective date of renewal \n is the first day \nof the fourth month following the close of the period \nfor renewal described in paragraph (d) of this section. \n(2) For renewed enrollment as an enrolled agent \nor enrolled retirement plan agent — \n(i) Requirements for enrollment cycle. A \nminimum of 72 hours of continuing education credit, \nincluding six hours of ethics or professional conduct, \nmust be completed during each enrollment cycle. \n(ii) Requirements for enrollment year. A \nminimum of 16 hours of continuing education credit, \nincluding two hours of ethics or professional conduct, \nmust be completed during each enrollment year of an \nenrollment cycle. \n(iii) Enrollment during enrollment cycle — \nPage 12 — § 10.6 \n(A) In general. Subject to paragraph (e)(2)(iii) \n(B) of this section, an individual who receives initial \nenrollment during an enrollment cycle must complete \ntwo hours of qualifying continuing education credit \nfor each month enrolled during the enrollment cycle. \nEnrollment for any part of a month is considered \nenrollment for the entire month. \n(3) Requirements for renewal as a registered \ntax return preparer. A minimum of 15 hours of \ncontinuing education credit, including two hours of \nethics or professional conduct, three hours of Federal \ntax law updates, and 10 hours of Federal tax law \ntopics, must be completed during each registration \nyear. \n(f) Qualifying continuing education — \n(1) General — \n(i) Enrolled agents. To qualify for continuing \n \neducation credit for an enrolled agent, a course of \nlearning must — \n(ii) Enrolled retirement plan agents. To qualify \nfor continuing education credit for an enrolled \nretirement plan agent, a course of learning must — \n(A) Be a qualifying continuing education \nprogram designed to enhance professional knowledge \nin qualified retirement plan matters; and \n(B) Be a qualifying continuing education \nprogram consistent with the Internal Revenue Code \nand effective tax administration. \n(iii) Registered tax return preparers. To \nTreasury Department Circular No. 230\nTable of Contents\n", " (A) Be a qualifying continuing education \nprogram \ndesigned \nto \nenhance \nprofessional \nknowledge in Federal taxation or Federal tax related \nmatters (programs comprised of current subject \nmatter in Federal taxation or Federal tax related \nmatters, including accounting, tax return preparation \nsoftware, taxation, or ethics); and \n (B) Be a qualifying continuing education \nprogram consistent with the Internal Revenue Code \nand effective tax administration. \nqualify for continuing education credit for a registered \ntax return preparer, a course of learning must — \n(2) Qualifying programs — \n(i) Formal programs. A formal program \nqualifies as a continuing education program if it — \n(A) Requires attendance and provides each \nattendee with a certificate of attendance; \n(B) Is conducted by a qualified instructor, \ndiscussion leader, or speaker (in other words, a \nperson whose background, training, education, and \nexperience is appropriate for instructing or leading \na discussion on the subject matter of the particular \nprogram); \n(C) Provides or requires a written outline, \ntextbook, or suitable electronic educational materials; \nand \n(D) Satisfies the requirements established for \na qualified continuing education program pursuant to \n§10.9. \n(ii) Correspondence or individual study \nprograms (including taped programs). Qualifying \ncontinuing \neducation \nprograms \ninclude \ncorrespondence or individual study programs that \nare conducted by continuing education providers \nand completed on an individual basis by the enrolled \nindividual. The allowable credit hours for such \nprograms will be measured on a basis comparable to \nthe measurement of a seminar or course for credit in \nan accredited educational institution. Such programs \nqualify as continuing education programs only if \nthey — \n(A) Require registration of the participants by \nthe continuing education provider; \n(B) Provide a means for measuring successful \ncompletion by the participants (for example, a written \nexamination), including the issuance of a certificate \nof completion by the continuing education provider; \n(C) Provide a written outline, textbook, or \nsuitable electronic educational materials; and \n(D) Satisfy the requirements established for a \nqualified continuing education program pursuant to \n§10.9. \n(iii) Serving as an instructor, discussion leader \nor speaker. \n(A) One hour of continuing education credit \nwill be awarded for each contact hour completed \nas an instructor, discussion leader, or speaker at \nan educational program that meets the continuing \neducation requirements of paragraph (f) of this \nsection. \n(B) A maximum of two hours of continuing \neducation credit will be awarded for actual subject \npreparation time for each contact hour completed as \nan instructor, discussion leader, or speaker at such \nprograms. It is the responsibility of the individual \nclaiming such credit to maintain records to verify \npreparation time. \n(C) The maximum continuing education credit \nfor instruction and preparation may not exceed four \nhours annually for registered tax return preparers and \nsix hours annually for enrolled agents and enrolled \nretirement plan agents. \n(D) An instructor, discussion leader, or \nspeaker who makes more than one presentation \non the same subject matter during an enrollment \ncycle or registration year will receive continuing \neducation credit for only one such presentation for \nthe enrollment cycle or registration year. \n(3) Periodic examination. Enrolled Agents and \nEnrolled Retirement Plan Agents may establish \neligibility for renewal of enrollment for any \nenrollment cycle by — \n(i) Achieving a passing score on each part of \nthe Special Enrollment Examination administered \nunder this part during the three year period prior to \nrenewal; and \n(ii) Completing a minimum of 16 hours of \nqualifying continuing education during the last year \nof an enrollment cycle. \nTreasury Department Circular No. 230\n§ 10.6 — Page 13 \nTable of Contents\n", "(g) \nMeasurement \nof \ncontinuing \neducation \ncoursework. \n(1) All continuing education programs will be \nmeasured in terms of contact hours. The shortest \nrecognized program will be one contact hour. \n(2) A contact hour is 50 minutes of continuous \nparticipation in a program. Credit is granted only for \na full contact hour, which is 50 minutes or multiples \nthereof. For example, a program lasting more than \n50 minutes but less than 100 minutes will count as \nonly one contact hour. \n(3) \nIndividual \nsegments \nat \ncontinuous \nconferences, conventions and the like will be \nconsidered one total program. For example, two \n90-minute segments (180 minutes) at a continuous \nconference will count as three contact hours. \n(4) For university or college courses, each \nsemester hour credit will equal 15 contact hours and \na quarter hour credit will equal 10 contact hours. \n(h) Recordkeeping requirements. \n(1) Each individual applying for renewal must \nretain for a period of four years following the date \nof renewal the information required with regard to \nqualifying continuing education credit hours. Such \ninformation includes — \n(i) The name of the sponsoring organization; \n(ii) The location of the program; \n(iii) The title of the program, qualified program \nnumber, and description of its content; \n(iv) Written outlines, course syllibi, textbook, \nand/or electronic materials provided or required for \nthe course; \n(v) The dates attended; \n(vi) The credit hours claimed; \n(vii) The name(s) of the instructor(s), discussion \nleader(s), or speaker(s), if appropriate; and \n(viii) The certificate of completion and/or \nsigned statement of the hours of attendance obtained \nfrom the continuing education provider. \n(2) To receive continuing education credit for \nservice completed as an instructor, discussion leader, \nor speaker, the following information must be \nmaintained for a period of four years following the \ndate of renewal — \n(i) The name of the sponsoring organization; \nPage 14 — § 10.6 \n(ii) The location of the program; \n(iii) The title of the program and copy of its \ncontent; \n(iv) The dates of the program; and \n(v) The credit hours claimed. \n(i) Waivers. \n(1) Waiver from the continuing education \nrequirements for a given period may be granted for \nthe following reasons — \n(i) Health, which prevented compliance with \nthe continuing education requirements; \n(ii) Extended active military duty; \n(iii) Absence from the United States for an \nextended period of time due to employment or other \nreasons, provided the individual does not practice \nbefore the Internal Revenue Service during such \nabsence; and \n(iv) Other compelling reasons, which will be \nconsidered on a case-by-case basis. \n(2) A request for waiver must be accompanied \nby appropriate documentation. The individual is \nrequired to furnish any additional documentation \nor explanation deemed necessary. Examples of \nappropriate documentation could be a medical \ncertificate or military orders. \n(3) A \n request for waiver must be filed no later \nthan the last day of the renewal application period. \n(4) If a request for waiver is not approved, the \nindividual will be placed in inactive status. The \nindividual will be notified that the waiver was not \napproved and that the individual has been placed on a \nroster of inactive enrolled agents, enrolled retirement \nplan agents, or registered tax return preparers. \n(5) If the request for waiver is not approved, the \nindividual may file a protest as prescribed by the \nInternal Revenue Service in forms, instructions, or \nother appropriate guidance. A \n protest filed under this \nsection is not governed by subpart D of this part. \n(6) If a request for waiver is approved, the \nindividual will be notified and issued a card or \ncertificate evidencing renewal. \n(7) Those who are granted waivers are required \nto file timely applications for renewal of enrollment \nor registration. \n(j) Failure to comply. \nTreasury Department Circular No. 230\nTable of Contents\n", " \n(1) Compliance by an individual with the \nrequirements of this part is determined by the Internal \nRevenue Service. The Internal Revenue Service \nwill provide notice to any individual who fails to \nmeet the continuing education and fee requirements \nof eligibility for renewal. The notice will state the \nbasis for the determination of noncompliance and \nwill provide the individual an opportunity to furnish \nthe requested information in writing relating to \nthe matter within 60 days of the date of the notice. \nSuch information will be considered in making a \nfinal determination as to eligibility for renewal. The \nindividual must be informed of the reason(s) for any \ndenial of a renewal. The individual may, within 30 \ndays after receipt of the notice of denial of renewal, \nfile a written protest of the denial as prescribed by \nthe Internal Revenue Service in forms, instructions, \nor other appropriate guidance. A protest under this \nsection is not governed by subpart D of this part. \n(2) The continuing education records of an \nenrolled agent, enrolled retirement plan agent, or \nregistered tax return preparer may be reviewed to \ndetermine compliance with the requirements and \nstandards for renewal as provided in paragraph (f) \nof this section. As part of this review, the enrolled \nagent, enrolled retirement plan agent or registered tax \nreturn preparer may be required to provide the Internal \nRevenue Service with copies of any continuing \neducation records required to be maintained under \nthis part. If the enrolled agent, enrolled retirement \nplan agent or registered tax return preparer fails \nto comply with this requirement, any continuing \neducation hours claimed may be disallowed. \n(3) An individual who has not filed a timely \napplication for renewal, who has not made a timely \nresponse to the notice of noncompliance with the \nrenewal requirements, or who has not satisfied \nthe requirements of eligibility for renewal will be \nplaced on a roster of inactive enrolled individuals \nor inactive registered individuals. During this time, \nthe individual will be ineligible to practice before the \nInternal Revenue Service. \n(4) Individuals placed in inactive status and \nindividuals ineligible to practice before the Internal \nRevenue Service may not state or imply that they \nTreasury Department Circular No. 230\nare eligible to practice before the Internal Revenue \nService, or use the terms enrolled agent, enrolled \nretirement plan agent, or registered tax return \npreparer, the designations “EA” or “ERPA” or other \nform of reference to eligibility to practice before the \nInternal Revenue Service. \n(5) An individual placed in inactive status \nmay be reinstated to an active status by filing an \napplication for renewal and providing evidence of \nthe completion of all required continuing education \nhours for the enrollment cycle or registration year. \nContinuing education credit under this paragraph (j) \n(5) may not be used to satisfy the requirements of \nthe enrollment cycle or registration year in which the \nindividual has been placed back on the active roster. \n(6) An individual placed in inactive status \nmust file an application for renewal and satisfy the \nrequirements for renewal as set forth in this section \nwithin three years of being placed in inactive \nstatus. Otherwise, the name of such individual will \nbe removed from the inactive status roster and the \nindividual’s status as an enrolled agent, enrolled \nretirement plan agent, or registered tax return \npreparer will terminate. Future eligibility for active \nstatus must then be reestablished by the individual as \nprovided in this section. \n(7) Inactive status is not available to an individual \nwho is the subject of a pending disciplinary matter \nbefore the Internal Revenue Service. \n(k) Inactive retirement status. An individual who no \nlonger practices before the Internal Revenue Service \nmay request to be placed in an inactive retirement \nstatus at any time and such individual will be placed \nin an inactive retirement status. The individual will \nbe ineligible to practice before the Internal Revenue \nService. An individual who is placed in an inactive \nretirement status may be reinstated to an active \nstatus by filing an application for renewal and \nproviding evidence of the completion of the required \ncontinuing education hours for the enrollment cycle \nor registration year. Inactive retirement status is not \navailable to an individual who is ineligible to practice \nbefore the Internal Revenue Service or an individual \nwho is the subject of a pending disciplinary matter \nunder this part. \n§ 10.6 — Page 15 \nTable of Contents\n", " \n \n \n \n \n \n \n(l) Renewal while under suspension or disbarment. \nAn individual who is ineligible to practice before the \nInternal Revenue Service by virtue of disciplinary \naction under this part is required to conform to the \nrequirements for renewal of enrollment or registration \nbefore the individual’s eligibility is restored. \n(m) Enrolled actuaries. The enrollment and renewal \nof enrollment of actuaries authorized to practice \nunder paragraph (d) of §10.3 are governed by the \nregulations of the Joint Board for the Enrollment of \nActuaries at 20 CFR 901.1 through 901.72. \n(n) Effective/applicability date. This section is \napplicable to enrollment or registration effective \nbeginning August 2, 2011. \n§ \n10.7 Representing \noneself; \nparticipating \nin rulemaking; limited practice; and special \nappearances. \n(a) Representing oneself. Individuals may appear on \ntheir own behalf before the Internal Revenue Service \nprovided they present satisfactory identification. \n(b) Participating in rulemaking. Individuals \nmay participate in rulemaking as provided by the \nAdministrative Procedure Act. See 5 U.S.C. § 553. \n(c) Limited practice — \n(1) In general. Subject to the limitations in \nparagraph (c)(2) of this section, an individual who \nis not a practitioner may represent a taxpayer before \nthe Internal Revenue Service in the circumstances \ndescribed in this paragraph (c)(1), even if the \ntaxpayer is not present, provided the individual \npresents satisfactory identification and proof of \nhis or her authority to represent the taxpayer. The \ncircumstances described in this paragraph (c)(1) are \nas follows: \n(i) An individual may represent a member of his \nor her immediate family. \n(ii)A regular full-time employee of an individual \nemployer may represent the employer. \n(iii) A general partner or a regular full-time \nemployee of a partnership may represent the \npartnership. \n(iv) A \n bona fide officer or a regular full-\ntime employee of a corporation (including a \nPage 16 — § 10.6 \nparent, subsidiary, or other affiliated corporation), \nassociation, or organized group may represent the \ncorporation, association, or organized group. \n(v) A regular full-time employee of a trust, \nreceivership, guardianship, or estate may represent \nthe trust, receivership, guardianship, or estate. \n(vi) An officer or a regular employee of \na governmental unit, agency, or authority may \nrepresent the governmental unit, agency, or authority \nin the course of his or her official duties. \n(vii) An individual may represent any individual \nor entity, who is outside the United States, before \npersonnel of the Internal Revenue Service when such \nrepresentation takes place outside the United States. \n(2) Limitations. \n(i) An individual who is under suspension or \ndisbarment from practice before the Internal Revenue \nService may not engage in limited practice before the \nInternal Revenue Service under paragraph (c)(1) of \nthis section. \n(ii) The Commissioner, or delegate, may, \nafter notice and opportunity for a conference, deny \neligibility to engage in limited practice before the \nInternal Revenue Service under paragraph (c)(1) of \nthis section to any individual who has engaged in \nconduct that would justify a sanction under §10.50. \n(iii) An individual who represents a taxpayer \nunder the authority of paragraph (c)(1) of this section \nis subject, to the extent of his or her authority, to such \nrules of general applicability regarding standards \nof conduct and other matters as prescribed by the \nInternal Revenue Service. \n(d) Special appearances. The Commissioner, \nor delegate, may, subject to conditions deemed \nappropriate, authorize an individual who is not \notherwise eligible to practice before the Internal \nRevenue Service to represent another person in a \nparticular matter. \n(e) Fiduciaries. For purposes of this part, a \nfiduciary (for example, a trustee, receiver, guardian, \npersonal representative, administrator, or executor) is \nconsidered to be the taxpayer and not a representative \nof the taxpayer. \n(f) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n§ 10.8 Return preparation and application of \nrules to other individuals. \n(a) Preparing all or substantially all of a tax return. \nAny individual who for compensation prepares or \nassists with the preparation of all or substantially \nall of a tax return or claim for refund must have \na preparer tax identification number. Except as \notherwise prescribed in forms, instructions, or other \nappropriate guidance, an individual must be an \nattorney, certified public accountant, enrolled agent, \nor registered tax return preparer to obtain a preparer \ntax identification number. Any individual who for \ncompensation prepares or assists with the preparation \nof all or substantially all of a tax return or claim for \nrefund is subject to the duties and restrictions relating \nto practice in subpart B, as well as subject to the \nsanctions for violation of the regulations in subpart C. \n(b) Preparing a tax return and furnishing \ninformation. Any individual may for compensation \nprepare or assist with the preparation of a tax return \nor claim for refund (provided the individual prepares \nless than substantially all of the tax return or claim for \nrefund), appear as a witness for the taxpayer before \nthe Internal Revenue Service, or furnish information \nat the request of the Internal Revenue Service or any \nof its officers or employees. \n(c) Application of rules to other individuals. Any \nindividual who for compensation prepares, or assists \nin the preparation of, all or a substantial portion of a \ndocument pertaining to any taxpayer’s tax liability for \nsubmission to the Internal Revenue Service is subject \nto the duties and restrictions relating to practice in \nsubpart B, as well as subject to the sanctions for \nviolation of the regulations in subpart C. Unless \notherwise a practitioner, however, an individual \nmay not for compensation prepare, or assist in the \npreparation of, all or substantially all of a tax return \nor claim for refund, or sign tax returns and claims for \nrefund. For purposes of this paragraph, an individual \ndescribed in 26 CFR 301.7701-15(f) is not treated \nas having prepared all or a substantial portion of the \ndocument by reason of such assistance. \n(d) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \n§ 10.9 Continuing education providers and \ncontinuing education programs. \n(a) Continuing education providers — \n(1) In general. Continuing education providers \nare those responsible for presenting continuing \neducation programs. A continuing education provider \nmust — \n(i) Be an accredited educational institution; \n(ii) Be recognized for continuing education \npurposes by the licensing body of any State, territory, \nor possession of the United States, including a \nCommonwealth, or the District of Columbia; \n(iii) Be recognized and approved by a qualifying \norganization as a provider of continuing education \non subject matters within §10.6(f) of this part. The \nInternal Revenue Service may, at its discretion, \nidentify a professional organization, society or \nbusiness entity that maintains minimum education \nstandards comparable to those set forth in this part as \na qualifying organization for purposes of this part in \nappropriate forms, instructions, and other appropriate \nguidance; or \n(iv) Be recognized by the Internal Revenue \nService as a professional organization, society, or \nbusiness whose programs include offering continuing \nprofessional education opportunities in subject \nmatters within §10.6(f) of this part. The Internal \nRevenue Service, at its discretion, may require such \nprofessional organizations, societies, or businesses \nto file an agreement and/or obtain Internal Revenue \nService approval of each program as a qualified \ncontinuing education program in appropriate forms, \ninstructions or other appropriate guidance. \n(2) Continuing education provider numbers — \n(i) In general. A continuing education provider \nis required to obtain a continuing education provider \nnumber and pay any applicable user fee. \n(ii) Renewal. A continuing education provider \nmaintains its status as a continuing education provider \nduring the continuing education provider cycle by \nrenewing its continuing education provider number as \nprescribed by forms, instructions or other appropriate \nguidance and paying any applicable user fee. \nTreasury Department Circular No. 230\n§ 10.9 — Page 17 \nTable of Contents\n", " \n(3) Requirements for qualified continuing \neducation programs. A continuing education \nprovider must ensure the qualified continuing \neducation program complies with all the following \nrequirements — \n(i) Programs must be developed by individual(s) \nqualified in the subject matter; \n(ii) Program subject matter must be current; \n(iii) Instructors, discussion leaders, and speakers \nmust be qualified with respect to program content; \n(iv) Programs must include some means for \nevaluation of the technical content and presentation \nto be evaluated; \n(v) Certificates of completion bearing a current \nqualified continuing education program number \nissued by the Internal Revenue Service must be \nprovided to the participants who successfully \ncomplete the program; and \n(vi) Records must be maintained by the \ncontinuing education provider to verify the \nparticipants who attended and completed the \nprogram for a period of four years following \ncompletion of the program. In the case of continuous \nconferences, conventions, and the like, records must \nbe maintained to verify completion of the program \nand attendance by each participant at each segment \nof the program. \n (4) Program numbers — \n(i) In general. Every continuing education \nprovider is required to obtain a continuing education \nprovider program number and pay any applicable \nuser fee for each program offered. Program \nnumbers shall be obtained as prescribed by forms, \ninstructions or other appropriate guidance. Although, \nat the discretion of the Internal Revenue Service, a \ncontinuing education provider may be required to \ndemonstrate that the program is designed to enhance \nprofessional knowledge in Federal taxation or \nFederal tax related matters (programs comprised \nof current subject matter in Federal taxation or \nFederal tax related matters, including accounting, tax \nreturn preparation software, taxation, or ethics) and \ncomplies with the requirements in paragraph (a)(2)of \nthis section before a program number is issued. \n(ii) Update programs. Update programs may \nuse the same number as the program subject to \nupdate. An update program is a program that instructs \non a change of existing law occurring within one \nyear of the update program offering. The qualifying \neducation program subject to update must have been \noffered within the two year time period prior to the \nchange in existing law. \n(iii) Change in existing law. A change in \nexisting law means the effective date of the statute or \nregulation, or date of entry of judicial decision, that \nis the subject of the update. \n(b) Failure to comply. Compliance by a continuing \neducation provider with the requirements of this part \nis determined by the Internal Revenue Service. A \ncontinuing education provider who fails to meet the \nrequirements of this part will be notified by the Internal \nRevenue Service. The notice will state the basis for \nthe determination of noncompliance and will provide \nthe continuing education provider an opportunity to \nfurnish the requested information in writing relating to \nthe matter within 60 days of the date of the notice. The \ncontinuing education provider may, within 30 days after \nreceipt of the notice of denial, file a written protest as \nprescribed by the Internal Revenue Service in forms, \ninstructions, or other appropriate guidance. A protest \nunder this section is not governed by subpart D of this \npart. \n(c) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \nPage 18 — § 10.9 \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \nSubpart B — Duties and Restrictions Relating to \nPractice Before the Internal Revenue Service \n(a) To the Internal Revenue Service. \n§ 10.20 Information to be furnished. \n(1) A practitioner must, on a proper and lawful \nrequest by a duly authorized officer or employee \nof the Internal Revenue Service, promptly submit \nrecords or information in any matter before the \nInternal Revenue Service unless the practitioner \nbelieves in good faith and on reasonable grounds that \nthe records or information are privileged. \n(2) Where the requested records or information \nare not in the possession of, or subject to the control \nof, the practitioner or the practitioner’s client, the \npractitioner must promptly notify the requesting \nInternal Revenue Service officer or employee and the \npractitioner must provide any information that the \npractitioner has regarding the identity of any person \nwho the practitioner believes may have possession or \ncontrol of the requested records or information. The \npractitioner must make reasonable inquiry of his or her \nclient regarding the identity of any person who may \nhave possession or control of the requested records \nor information, but the practitioner is not required to \nmake inquiry of any other person or independently \nverify any information provided by the practitioner’s \nclient regarding the identity of such persons. \n(3) When a proper and lawful request is made \nby a duly authorized officer or employee of the \nInternal Revenue Service, concerning an inquiry \ninto an alleged violation of the regulations in this \npart, a practitioner must provide any information the \npractitioner has concerning the alleged violation and \ntestify regarding this information in any proceeding \ninstituted under this part, unless the practitioner \nbelieves in good faith and on reasonable grounds that \nthe information is privileged. \n(b) Interference with a proper and lawful request \nfor records or information. A practitioner may not \ninterfere, or attempt to interfere, with any proper \nand lawful effort by the Internal Revenue Service, \nits officers or employees, to obtain any record or \ninformation unless the practitioner believes in good \nTreasury Department Circular No. 230\nfaith and on reasonable grounds that the record or \ninformation is privileged. \n(c) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.21 Knowledge of client’s omission. \nA practitioner who, having been retained by a \nclient with respect to a matter administered by the \nInternal Revenue Service, knows that the client has \nnot complied with the revenue laws of the United \nStates or has made an error in or omission from any \nreturn, document, affidavit, or other paper which \nthe client submitted or executed under the revenue \nlaws of the United States, must advise the client \npromptly of the fact of such noncompliance, error, \nor omission. The practitioner must advise the client \nof the consequences as provided under the Code \nand regulations of such noncompliance, error, or \nomission. \n§ 10.22 Diligence as to accuracy. \n(a) In general. \n A practitioner must exercise due \ndiligence — \n(1) In preparing or assisting in the preparation \nof, approving, and filing tax returns, documents, \naffidavits, and other papers relating to Internal \nRevenue Service matters; \n(2) In determining the correctness of oral or \nwritten representations made by the practitioner to \nthe Department of the Treasury; and \n(3) In determining the correctness of oral or \nwritten representations made by the practitioner to \nclients with reference to any matter administered by \nthe Internal Revenue Service. \n(b) Reliance on others. \n Except as modified by \n§§10.34 and 10.37, a practitioner will be presumed \nto have exercised due diligence for purposes of \nthis section if the practitioner relies on the work \nproduct of another person and the practitioner used \nreasonable care in engaging, supervising, training, \nand evaluating the person, taking proper account of \nthe nature of the relationship between the practitioner \nand the person. \n§ 10.22 — Page 19 \nTable of Contents\n", " \n \n \n \n(c) Effective/applicability date. Paragraph (a) of \nthis section is applicable on September 26, 2007. \nParagraph (b) of this section is applicable beginning \nJune 12, 2014. \n§ 10.23 Prompt disposition of pending matters. \nA practitioner may not unreasonably delay the \nprompt disposition of any matter before the Internal \nRevenue Service. \n§ 10.24 Assistance from or to disbarred or \nsuspended persons and former Internal Revenue \nService employees. \nA practitioner may not, knowingly and directly or \nindirectly: \n(a) Accept assistance from or assist any person \nwho is under disbarment or suspension from practice \nbefore the Internal Revenue Service if the assistance \nrelates to a matter or matters constituting practice \nbefore the Internal Revenue Service. \n(b) Accept assistance from any former government \nemployee where the provisions of § 10.25 or any \nFederal law would be violated. \n§ 10.25 Practice by former government employees, \ntheir partners and their associates. \n(a) Definitions. For purposes of this section — \n(1) Assist means to act in such a way as to advise, \nfurnish information to, or otherwise aid another \nperson, directly, or indirectly. \n(2) Government employee \n is an officer or \nemployee of the United States or any agency of \nthe United States, including a special Government \nemployee as defined in 18 U.S.C. 202(a), or of the \nDistrict of Columbia, or of any State, or a member of \nCongress or of any State legislature. \n(3) Member of a firm is a sole practitioner or \nan employee or associate thereof, or a partner, \nstockholder, associate, affiliate or employee of a \npartnership, joint venture, corporation, professional \nassociation or other affiliation of two or more \npractitioners \nwho \nrepresent \nnongovernmental \nparties. \nPage 20 — § 10.22 \n(4) Particular matter involving specific parties is \ndefined at 5 CFR 2637.201(c), or superseding post-\nemployment regulations issued by the U.S. Office of \nGovernment Ethics. \n(5) Rule includes Treasury regulations, whether \nissued or under preparation for issuance as notices \nof proposed rulemaking or as Treasury decisions, \nrevenue rulings, and revenue procedures published \nin the Internal Revenue Bulletin (see 26 CFR \n601.601(d)(2)(ii)(b)). \n(b) General rules — \n(1) No former Government employee may, \nsubsequent to Government employment, represent \nanyone in any matter administered by the Internal \nRevenue Service if the representation would violate \n18 U.S.C. 207 or any other laws of the United States. \n(2) No former Government employee who \npersonally and substantially participated in a \nparticular matter involving specific parties may, \nsubsequent to Government employment, represent \nor knowingly assist, in that particular matter, any \nperson who is or was a specific party to that particular \nmatter. \n(3) A former Government employee who within \na period of one year prior to the termination of \nGovernment employment had official responsibility \nfor a particular matter involving specific parties may \nnot, within two years after Government employment \nis ended, represent in that particular matter any person \nwho is or was a specific party to that particular matter. \n(4) No former Government employee may, within \none year after Government employment is ended, \ncommunicate with or appear before, with the intent to \ninfluence, any employee of the Treasury Department \nin connection with the publication, withdrawal, \namendment, modification, or interpretation of a rule \nthe development of which the former Government \nemployee participated in, or for which, within a period \nof one year prior to the termination of Government \nemployment, the former government employee had \nofficial responsibility. This paragraph (b)(4) does \nnot, however, preclude any former employee from \nappearing on one’s own behalf or from representing \na taxpayer before the Internal Revenue Service in \nconnection with a particular matter involving specific \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n \n \n \nparties involving the application or interpretation of \na rule with respect to that particular matter, provided \nthat the representation is otherwise consistent with \nthe other provisions of this section and the former \nemployee does not utilize or disclose any confidential \ninformation acquired by the former employee in the \ndevelopment of the rule. \n(c) Firm representation — \n(1) No member of a firm of which a former \nGovernment employee is a member may represent \nor knowingly assist a person who was or is a specific \nparty in any particular matter with respect to which \nthe restrictions of paragraph (b)(2) of this section \napply to the former Government employee, in that \nparticular matter, unless the firm isolates the former \nGovernment employee in such a way to ensure that \nthe former Government employee cannot assist in \nthe representation. \n(2) When isolation of a former Government \nemployee is required under paragraph (c)(1) of \nthis section, a statement affirming the fact of such \nisolation must be executed under oath by the former \nGovernment employee and by another member of the \nfirm acting on behalf of the firm. The statement must \nclearly identify the firm, the former Government \nemployee, and the particular matter(s) requiring \nisolation. The statement must be retained by the firm \nand, upon request, provided to the office(s) of the \nInternal Revenue Service administering or enforcing \nthis part. \n(d) Pending representation. The provisions of \nthis regulation will govern practice by former \nGovernment \nemployees, \ntheir \npartners \nand \nassociates with respect to representation in particular \nmatters involving specific parties where actual \nrepresentation commenced before the effective date \nof this regulation. \n(e) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.26 Notaries. \nA practitioner may not take acknowledgments, \nadminister oaths, certify papers, or perform any \nofficial act as a notary public with respect to any \nTreasury Department Circular No. 230\nmatter administered by the Internal Revenue Service \nand for which he or she is employed as counsel, \nattorney, or agent, or in which he or she may be in any \nway interested. \n§ 10.27 Fees. \n(a) In general. \n A practitioner may not charge an \nunconscionable fee in connection with any matter \nbefore the Internal Revenue Service. \n(b) Contingent fees — \n(1) Except as provided in paragraphs (b)(2), (3), \nand (4) of this section, a practitioner may not charge \na contingent fee for services rendered in connection \nwith any matter before the Internal Revenue Service. \n(2) A practitioner may charge a contingent \nfee for services rendered in connection with the \nService’s examination of, or challenge to — \n(i) An original tax return; or \n(ii) An amended return or claim for refund or \ncredit where the amended return or claim for refund \nor credit was filed within 120 days of the taxpayer \nreceiving a written notice of the examination of, or a \nwritten challenge to the original tax return. \n(3) A practitioner may charge a contingent fee \nfor services rendered in connection with a claim \nfor credit or refund filed solely in connection with \nthe determination of statutory interest or penalties \nassessed by the Internal Revenue Service. \n(4) A \n practitioner may charge a contingent fee \nfor services rendered in connection with any judicial \nproceeding arising under the Internal Revenue Code. \n(c) Definitions. For purposes of this section — \n(1) Contingent fee is any fee that is based, in \nwhole or in part, on whether or not a position taken \non a tax return or other filing avoids challenge by \nthe Internal Revenue Service or is sustained either \nby the Internal Revenue Service or in litigation. \nA contingent fee includes a fee that is based on a \npercentage of the refund reported on a return, that \nis based on a percentage of the taxes saved, or that \notherwise depends on the specific result attained. A \ncontingent fee also includes any fee arrangement \nin which the practitioner will reimburse the client \nfor all or a portion of the client’s fee in the event \n§ 10.27 — Page 21 \nTable of Contents\n", " \n \n \nthat a position taken on a tax return or other filing \nis challenged by the Internal Revenue Service or \nis not sustained, whether pursuant to an indemnity \nagreement, a guarantee, rescission rights, or any \nother arrangement with a similar effect. \n(2) Matter before the Internal Revenue Service \nincludes tax planning and advice, preparing or filing \nor assisting in preparing or filing returns or claims \nfor refund or credit, and all matters connected with \na presentation to the Internal Revenue Service \nor any of its officers or employees relating to a \ntaxpayer’s rights, privileges, or liabilities under \nlaws or regulations administered by the Internal \nRevenue Service. Such presentations include, but \nare not limited to, preparing and filing documents, \ncorresponding and communicating with the Internal \nRevenue Service, rendering written advice with \nrespect to any entity, transaction, plan or arrangement, \nand representing a client at conferences, hearings, \nand meetings. \n(d) Effective/applicability date. This section is \napplicable for fee arrangements entered into after \nMarch 26, 2008. \n§ 10.28 Return of client’s records. \n(a) In general, a practitioner must, at the request of \na client, promptly return any and all records of the \nclient that are necessary for the client to comply with \nhis or her Federal tax obligations. The practitioner \nmay retain copies of the records returned to a client. \nThe existence of a dispute over fees generally does \nnot relieve the practitioner of his or her responsibility \nunder this section. Nevertheless, if applicable state law \nallows or permits the retention of a client’s records by \na practitioner in the case of a dispute over fees for \nservices rendered, the practitioner need only return \nthose records that must be attached to the taxpayer’s \nreturn. The practitioner, however, must provide the \nclient with reasonable access to review and copy \nany additional records of the client retained by the \npractitioner under state law that are necessary for the \nclient to comply with his or her Federal tax obligations. \n(b) For purposes of this section — Records of the \nclient include all documents or written or electronic \nPage 22 — § 10.27 \nmaterials provided to the practitioner, or obtained \nby the practitioner in the course of the practitioner’s \nrepresentation of the client, that preexisted the \nretention of the practitioner by the client. The term also \nincludes materials that were prepared by the client or a \nthird party (not including an employee or agent of the \npractitioner) at any time and provided to the practitioner \nwith respect to the subject matter of the representation. \nThe term also includes any return, claim for refund, \nschedule, affidavit, appraisal or any other document \nprepared by the practitioner, or his or her employee or \nagent, that was presented to the client with respect to \na prior representation if such document is necessary \nfor the taxpayer to comply with his or her current \nFederal tax obligations. The term does not include any \nreturn, claim for refund, schedule, affidavit, appraisal \nor any other document prepared by the practitioner \nor the practitioner’s firm, employees or agents if the \npractitioner is withholding such document pending the \nclient’s performance of its contractual obligation to pay \nfees with respect to such document. \n§ 10.29 Conflicting interests. \n(a) Except as provided by paragraph (b) of \nthis section, a practitioner shall not represent a \nclient before the Internal Revenue Service if the \nrepresentation involves a conflict of interest. A \nconflict of interest exists if — \n(1) The representation of one client will be \ndirectly adverse to another client; or \n(2)There is a significant risk that the representation \nof one or more clients will be materially limited by \nthe practitioner’s responsibilities to another client, \na former client or a third person, or by a personal \ninterest of the practitioner. \n(b) Notwithstanding the existence of a conflict \nof interest under paragraph (a) of this section, the \npractitioner may represent a client if — \n(1) The practitioner reasonably believes that the \npractitioner will be able to provide competent and \ndiligent representation to each affected client; \n(2) \n The representation is not prohibited by law; \n \nand \n \n(3) Each affected client waives the conflict of \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \ninterest and gives informed consent, confirmed \nin writing by each affected client, at the time the \nexistence of the conflict of interest is known by the \npractitioner. The confirmation may be made within a \nreasonable period of time after the informed consent, \nbut in no event later than 30 days. \n(c) Copies of the written consents must be retained \nby the practitioner for at least 36 months from the \ndate of the conclusion of the representation of the \naffected clients, and the written consents must be \nprovided to any officer or employee of the Internal \nRevenue Service on request. \n(d) Effective/applicability date. This section is \napplicable on September 26, 2007. \n§ 10.30 Solicitation. \n(a) Advertising and solicitation restrictions. \n \n(1) A practitioner may not, with respect to \nany Internal Revenue Service matter, in any way \nuse or participate in the use of any form of public \ncommunication or private solicitation containing a \nfalse, fraudulent, or coercive statement or claim; or a \nmisleading or deceptive statement or claim. Enrolled \nagents, enrolled retirement plan agents, or registered \ntax return preparers, in describing their professional \ndesignation, may not utilize the term “certified” or \nimply an employer/employee relationship with the \nInternal Revenue Service. Examples of acceptable \ndescriptions for enrolled agents are “enrolled to \nrepresent taxpayers before the Internal Revenue \nService,” “enrolled to practice before the Internal \nRevenue Service,” and “admitted to practice before \nthe Internal Revenue Service.” Similarly, examples \nof acceptable descriptions for enrolled retirement \nplan agents are “enrolled to represent taxpayers \nbefore the Internal Revenue Service as a retirement \nplan agent” and “enrolled to practice before the \nInternal Revenue Service as a retirement plan \nagent.” An example of an acceptable description for \nregistered tax return preparers is “designated as a \nregistered tax return preparer by the Internal Revenue \nService.” \n(2) A practitioner may not make, directly or \nindirectly, an uninvited written or oral solicitation \nTreasury Department Circular No. 230\nof employment in matters related to the Internal \nRevenue Service if the solicitation violates Federal \nor State law or other applicable rule, e.g., attorneys \nare precluded from making a solicitation that is \nprohibited by conduct rules applicable to all attorneys \nin their State(s) of licensure. Any lawful solicitation \nmade by or on behalf of a practitioner eligible to \npractice before the Internal Revenue Service must, \nnevertheless, clearly identify the solicitation as \nsuch and, if applicable, identify the source of the \ninformation used in choosing the recipient. \n(b) Fee information. \n(1)(i) A practitioner may publish the availability \nof a written schedule of fees and disseminate the \nfollowing fee information — \n(A) Fixed fees for specific routine services. \n(B) Hourly rates. \n(C) Range of fees for particular services. \n(D) Fee charged for an initial consultation. \n(ii)Any statement of fee information concerning \nmatters in which costs may be incurred must include \na statement disclosing whether clients will be \nresponsible for such costs. \n(2) A practitioner may charge no more than the \nrate(s) published under paragraph (b)(1) of this \nsection for at least 30 calendar days after the last date \non which the schedule of fees was published. \n(c) Communication of fee information. Fee \ninformation may be communicated in professional \nlists, telephone directories, print media, mailings, \nand electronic mail, facsimile, hand delivered \nflyers, radio, television, and any other method. \nThe method chosen, however, must not cause the \ncommunication to become untruthful, deceptive, \nor otherwise in violation of this part. A practitioner \nmay not persist in attempting to contact a prospective \nclient if the prospective client has made it known \nto the practitioner that he or she does not desire \nto be solicited. In the case of radio and television \nbroadcasting, the broadcast must be recorded \nand the practitioner must retain a recording of the \nactual transmission. In the case of direct mail and \ne-commerce communications, the practitioner must \nretain a copy of the actual communication, along \nwith a list or other description of persons to whom the \n§ 10.30 — Page 23 \nTable of Contents\n", " \n \n \n \ncommunication was mailed or otherwise distributed. \nThe copy must be retained by the practitioner for a \nperiod of at least 36 months from the date of the last \ntransmission or use. \n(d) Improper associations. \n A practitioner may not, \nin matters related to the Internal Revenue Service, \nassist, or accept assistance from, any person or entity \nwho, to the knowledge of the practitioner, obtains \nclients or otherwise practices in a manner forbidden \nunder this section. \n(e) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n(Approved by the Office of Management and Budget \nunder Control No. 1545-1726) \n§ 10.31 Negotiation of taxpayer checks.\n (a) A practitioner may not endorse or otherwise \nnegotiate any check (including directing or accepting \npayment by any means, electronic or otherwise, into \nan account owned or controlled by the practitioner or \nany firm or other entity with whom the practitioner \nis associated) issued to a client by the government in \nrespect of a Federal tax liability. \n(b) Effective/applicability date. \n This section is \napplicable beginning June 12, 2014. \n§ 10.32 Practice of law. \nNothing in the regulations in this part may be \nconstrued as authorizing persons not members of the \nbar to practice law. \n§ 10.33 Best practices for tax advisors. \n(a) Best practices. \n Tax advisors should provide \nclients with the highest quality representation \nconcerning Federal tax issues by adhering to best \npractices in providing advice and in preparing or \nassisting in the preparation of a submission to the \nInternal Revenue Service. In addition to compliance \nwith the standards of practice provided elsewhere in \nthis part, best practices include the following: \n(1) Communicating clearly with the client \nPage 24 — § 10.30 \nregarding the terms of the engagement. For example, \nthe advisor should determine the client’s expected \npurpose for and use of the advice and should have \na clear understanding with the client regarding the \nform and scope of the advice or assistance to be \nrendered. \n(2) Establishing the facts, determining which \nfacts are relevant, evaluating the reasonableness \nof any assumptions or representations, relating the \napplicable law (including potentially applicable \njudicial doctrines) to the relevant facts, and arriving \nat a conclusion supported by the law and the facts. \n(3) Advising the client regarding the import of \nthe conclusions reached, including, for example, \nwhether a taxpayer may avoid accuracy-related \npenalties under the Internal Revenue Code if a \ntaxpayer acts in reliance on the advice. \n(4) Acting fairly and with integrity in practice \nbefore the Internal Revenue Service. \n(b) Procedures to ensure best practices for tax \nadvisors. Tax advisors with responsibility for \noverseeing a firm’s practice of providing advice \nconcerning Federal tax issues or of preparing or \nassisting in the preparation of submissions to the \nInternal Revenue Service should take reasonable steps \nto ensure that the firm’s procedures for all members, \nassociates, and employees are consistent with the best \npractices set forth in paragraph (a) of this section. \n(c) Applicability date. \n This section is effective after \nJune 20, 2005. \n§ 10.34 \n Standards with respect to tax returns and \ndocuments, affidavits and other papers. \n(a) Tax returns. \n(1) A practitioner may not willfully, recklessly, or \nthrough gross incompetence — \n(i) Sign a tax return or claim for refund that \nthe practitioner knows or reasonably should know \ncontains a position that — \n(A) Lacks a reasonable basis; \n(B) Is an unreasonable position as described \nin section 6694(a)(2) of the Internal Revenue Code \n(Code) (including the related regulations and other \npublished guidance); or \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n(C) Is a willful attempt by the practitioner \nto understate the liability for tax or a reckless or \nintentional disregard of rules or regulations by the \npractitioner as described in section 6694(b)(2) of the \nCode (including the related regulations and other \npublished guidance). \n(ii) Advise a client to take a position on a tax \nreturn or claim for refund, or prepare a portion of a \ntax return or claim for refund containing a position, \nthat — \n(A) Lacks a reasonable basis; \n(B) Is an unreasonable position as described \nin section 6694(a)(2) of the Code (including the \nrelated regulations and other published guidance); or \n(C) Is a willful attempt by the practitioner \nto understate the liability for tax or a reckless or \nintentional disregard of rules or regulations by the \npractitioner as described in section 6694(b)(2) of the \nCode (including the related regulations and other \npublished guidance). \n(2) A pattern of conduct is a factor that will \nbe taken into account in determining whether a \npractitioner acted willfully, recklessly, or through \ngross incompetence. \n(b) Documents, affidavits and other papers — \n(1) A practitioner may not advise a client to take \na position on a document, affidavit or other paper \nsubmitted to the Internal Revenue Service unless the \nposition is not frivolous. \n(2) A \n practitioner may not advise a client to \nsubmit a document, affidavit or other paper to the \nInternal Revenue Service — \n(i) The purpose of which is to delay or impede \nthe administration of the Federal tax laws; \n(ii) That is frivolous; or \n(iii) That contains or omits information in a \nmanner that demonstrates an intentional disregard \nof a rule or regulation unless the practitioner also \nadvises the client to submit a document that evidences \na good faith challenge to the rule or regulation. \n \n(c) Advising clients on potential penalties — \n(1) A practitioner must inform a client of any \npenalties that are reasonably likely to apply to the \nclient with respect to — \n(i) A position taken on a tax return if — \nTreasury Department Circular No. 230\n(A) The practitioner advised the client with \nrespect to the position; or \n(B) The practitioner prepared or signed the tax \nreturn; and \n(ii) Any document, affidavit or other paper \nsubmitted to the Internal Revenue Service. \n(2) The practitioner also must inform the client \nof any opportunity to avoid any such penalties by \ndisclosure, if relevant, and of the requirements for \nadequate disclosure. \n(3) This paragraph (c) applies even if the \npractitioner is not subject to a penalty under the \nInternal Revenue Code with respect to the position \nor with respect to the document, affidavit or other \npaper submitted. \n(d) Relying on information furnished by \nclients. A practitioner advising a client to take \na position on a tax return, document, affidavit or \nother paper submitted to the Internal Revenue \nService, or preparing or signing a tax return as a \npreparer, generally may rely in good faith without \nverification upon information furnished by the \nclient. The practitioner may not, however, ignore the \nimplications of information furnished to, or actually \nknown by, the practitioner, and must make reasonable \ninquiries if the information as furnished appears to \nbe incorrect, inconsistent with an important fact or \nanother factual assumption, or incomplete. \n(e) Effective/applicability date. Paragraph (a) of \nthis section is applicable for returns or claims for \nrefund filed, or advice provided, beginning August 2, \n2011. Paragraphs (b) through (d) of this section are \napplicable to tax returns, documents, affidavits, and \nother papers filed on or after September 26, 2007. \n§ 10.35 Competence. \n(a) A practitioner must possess the necessary \ncompetence to engage in practice before the Internal \nRevenue Service. Competent practice requires the \nappropriate level of knowledge, skill, thoroughness, \nand preparation necessary for the matter for which the \npractitioner is engaged. A \n practitioner may become \ncompetent for the matter for which the practitioner \nhas been engaged through various methods, such \n§ 10.35 — Page 25 \nTable of Contents\n", " \n \n \n \nas consulting with experts in the relevant area or \nstudying the relevant law. \n(b) Effective/applicability date. This section is \napplicable beginning June 12, 2014. \n§ 10.36 Procedures to ensure compliance. \n(a) Any individual subject to the provisions of this \npart who has (or individuals who have or share) \nprincipal authority and responsibility for overseeing \na firm’s practice governed by this part, including the \nprovision of advice concerning Federal tax matters \nand preparation of tax returns, claims for refund, \nor other documents for submission to the Internal \nRevenue Service, must take reasonable steps to \nensure that the firm has adequate procedures in \neffect for all members, associates, and employees \nfor purposes of complying with subparts A, B, and \nC of this part, as applicable. In the absence of a \nperson or persons identified by the firm as having \nthe principal authority and responsibility described \nin this paragraph, the Internal Revenue Service \nmay identify one or more individuals subject to the \nprovisions of this part responsible for compliance \nwith the requirements of this section. \n(b) Any such individual who has (or such \nindividuals who have or share) principal authority \nas described in paragraph (a) of this section will be \nsubject to discipline for failing to comply with the \nrequirements of this section if— \n(1) \nThe \nindividual \nthrough \nwillfulness, \nrecklessness, or gross incompetence does not take \nreasonable steps to ensure that the firm has adequate \nprocedures to comply with this part, as applicable, \nand one or more individuals who are members of, \nassociated with, or employed by, the firm are, or \nhave, engaged in a pattern or practice, in connection \nwith their practice with the firm, of failing to comply \nwith this part, as applicable; \n(2) \nThe \nindividual \nthrough \nwillfulness, \nrecklessness, or gross incompetence does not take \nreasonable steps to ensure that firm procedures \nin effect are properly followed, and one or more \nindividuals who are members of, associated with, \nor employed by, the firm are, or have, engaged in a \nPage 26 — § 10.35 \npattern or practice, in connection with their practice \nwith the firm, of failing to comply with this part, as \napplicable; or \n(3) The individual knows or should know that one \nor more individuals who are members of, associated \nwith, or employed by, the firm are, or have, engaged \nin a pattern or practice, in connection with their \npractice with the firm, that does not comply with \nthis part, as applicable, and the individual, through \nwillfulness, recklessness, or gross incompetence fails \nto take prompt action to correct the noncompliance. \n(c) Effective/applicability date. \n This section is \napplicable beginning June 12, 2014. \n§ 10.37 Requirements for written advice. \n(a) Requirements. \n \n(1) A practitioner may give written advice \n(including by means of electronic communication) \nconcerning one or more Federal tax matters subject to \nthe requirements in paragraph (a)(2) of this section. \nGovernment submissions on matters of general \npolicy are not considered written advice on a Federal \ntax matter for purposes of this section. Continuing \neducation presentations provided to an audience \nsolely for the purpose of enhancing practitioners’ \nprofessional knowledge on Federal tax matters \nare not considered written advice on a Federal tax \nmatter for purposes of this section. The preceding \nsentence does not apply to presentations marketing \nor promoting transactions. \n(2) The practitioner must— \n(i) Base the written advice on reasonable factual \nand legal assumptions (including assumptions as to \nfuture events); \n(ii) Reasonably consider all relevant facts \nand circumstances that the practitioner knows or \nreasonably should know; \n(iii) Use reasonable efforts to identify and \nascertain the facts relevant to written advice on each \nFederal tax matter; \n(iv) Not rely upon representations, statements, \nfindings, or agreements (including projections, \nfinancial forecasts, or appraisals) of the taxpayer \nor any other person if reliance on them would be \nunreasonable; \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n(v) Relate applicable law and authorities to \nfacts; and \n(vi) Not, in evaluating a Federal tax matter, take \ninto account the possibility that a tax return will not \nbe audited or that a matter will not be raised on audit. \n(3) Reliance on representations, statements, \nfindings, or agreements is unreasonable if the \npractitioner knows or reasonably should know that \none or more representations or assumptions on which \nany representation is based are incorrect, incomplete, \nor inconsistent. \n(b) Reliance on advice of others. A \n practitioner \nmay only rely on the advice of another person if the \nadvice was reasonable and the reliance is in good \nfaith considering all the facts and circumstances. \nReliance is not reasonable when— \n(1) The practitioner knows or reasonably should \nknow that the opinion of the other person should not \nbe relied on; \n(2) The practitioner knows or reasonably should \nknow that the other person is not competent or lacks \nthe necessary qualifications to provide the advice; or \n(3) The practitioner knows or reasonably should \nknow that the other person has a conflict of interest in \nviolation of the rules described in this part. \n(c) Standard of review. \n(1) In evaluating whether a practitioner giving \nwritten advice concerning one or more Federal \ntax matters complied with the requirements of this \nsection, the Commissioner, or delegate, will apply a \nreasonable practitioner standard, considering all facts \nand circumstances, including, but not limited to, the \nscope of the engagement and the type and specificity \nof the advice sought by the client. \n(2) In the case of an opinion the practitioner \nknows or has reason to know will be used or referred \nto by a person other than the practitioner (or a person \nwho is a member of, associated with, or employed by \nthe practitioner’s firm) in promoting, marketing, or \nrecommending to one or more taxpayers a partnership \nor other entity, investment plan or arrangement \na significant purpose of which is the avoidance or \nevasion of any tax imposed by the Internal Revenue \nCode, the Commissioner, or delegate, will apply a \nreasonable practitioner standard, considering all \nfacts and circumstances, with emphasis given to the \nadditional risk caused by the practitioner’s lack of \nknowledge of the taxpayer’s particular circumstances, \nwhen determining whether a practitioner has failed \nto comply with this section. \n(d) Federal tax matter. \n A Federal tax matter, as \nused in this section, is any matter concerning the \napplication or interpretation of---\n(1) A \n revenue provision as defined in section \n6110(i)(1)(B) of the Internal Revenue Code; \n(2) Any provision of law impacting a person’s \nobligations under the internal revenue laws and \nregulations, including but not limited to the person’s \nliability to pay tax or obligation to file returns; or \n(3) Any other law or regulation administered by \nthe Internal Revenue Service. \n(e) Effective/applicability date. \n This section is \napplicable to written advice rendered after June 12, \n2014. \n§ 10.38 Establishment of advisory committees. \n(a) Advisory committees. To promote and maintain \nthe public’s confidence in tax advisors, the Internal \nRevenue Service is authorized to establish one or \nmore advisory committees composed of at least \nsix individuals authorized to practice before the \nInternal Revenue Service. Membership of an \nadvisory committee must be balanced among those \nwho practice as attorneys, accountants, enrolled \nagents, enrolled actuaries, enrolled retirement plan \nagents, and registered tax return preparers. Under \nprocedures prescribed by the Internal Revenue \nService, an advisory committee may review and make \ngeneral recommendations regarding the practices, \nprocedures, and policies of the offices described in \n§10.1. \n(b) Effective date. \n This section is applicable \nbeginning August 2, 2011. \nTreasury Department Circular No. 230\n§ 10.38 — Page 27 \nTable of Contents\n", " \n \n \n \nSubpart C — Sanctions for Violation of the \nRegulations \n§ 10.50 Sanctions. \n(a) Authority to censure, suspend, or disbar. The \nSecretary of the Treasury, or delegate, after notice \nand an opportunity for a proceeding, may censure, \nsuspend, or disbar any practitioner from practice \nbefore the Internal Revenue Service if the practitioner \nis shown to be incompetent or disreputable (within \nthe meaning of §10.51), fails to comply with any \nregulation in this part (under the prohibited conduct \nstandards of §10.52), or with intent to defraud, \nwillfully and knowingly misleads or threatens a client \nor prospective client. Censure is a public reprimand. \n(b) Authority \n to disqualify. The Secretary of the \nTreasury, or delegate, after due notice and opportunity \nfor hearing, may disqualify any appraiser for a \nviolation of these rules as applicable to appraisers. \n(1) If any appraiser is disqualified pursuant \nto this subpart C, the appraiser is barred from \npresenting \nevidence \nor \ntestimony \nin \nany \nadministrative proceeding before the Department \nof Treasury or the Internal Revenue Service, \nunless and until authorized to do so by the Internal \nRevenue Service pursuant to §10.81, regardless of \nwhether the evidence or testimony would pertain \nto an appraisal made prior to or after the effective \ndate of disqualification. \n(2) Any appraisal made by a disqualified \nappraiser after the effective date of disqualification \nwill not have any probative effect in any \nadministrative proceeding before the Department \nof the Treasury or the Internal Revenue Service. \nAn appraisal otherwise barred from admission into \nevidence pursuant to this section may be admitted into \nevidence solely for the purpose of determining the \ntaxpayer’s reliance in good faith on such appraisal. \n(c) Authority to impose monetary penalty — \n \n(1) In general. \n \n(i) The Secretary of the Treasury, or delegate, \nafter notice and an opportunity for a proceeding, \nmay impose a monetary penalty on any practitioner \nwho engages in conduct subject to sanction under \nPage 28 — § 10.50 \nparagraph (a) of this section. \n(ii) If the practitioner described in paragraph \n(c)(1)(i) of this section was acting on behalf of an \nemployer or any firm or other entity in connection \nwith the conduct giving rise to the penalty, the \nSecretary of the Treasury, or delegate, may impose \na monetary penalty on the employer, firm, or entity \nif it knew, or reasonably should have known of such \nconduct. \n(2) Amount of penalty. \n The amount of the penalty \nshall not exceed the gross income derived (or to be \nderived) from the conduct giving rise to the penalty. \n(3) Coordination with other sanctions. Subject to \nparagraph (c)(2) of this section — \n(i) Any monetary penalty imposed on a \npractitioner under this paragraph (c) may be in \naddition to or in lieu of any suspension, disbarment or \ncensure and may be in addition to a penalty imposed \non an employer, firm or other entity under paragraph \n(c)(1)(ii) of this section. \n(ii) Any monetary penalty imposed on an \nemployer, firm or other entity may be in addition to \nor in lieu of penalties imposed under paragraph (c) \n(1)(i) of this section. \n(d) Authority to accept a practitioner’s consent to \nsanction. The Internal Revenue Service may accept \na practitioner’s offer of consent to be sanctioned \nunder §10.50 in lieu of instituting or continuing a \nproceeding under §10.60(a). \n(e) Sanctions to be imposed. \n The sanctions imposed \nby this section shall take into account all relevant \nfacts and circumstances. \n(f) Effective/applicability date. This section is \napplicable to conduct occurring on or after August 2, \n2011, except that paragraphs (a), (b)(2), and (e) apply \nto conduct occurring on or after September 26, 2007, \nand paragraph (c) applies to prohibited conduct that \noccurs after October 22, 2004. \n§ 10.51 Incompetence and disreputable conduct. \n(a) Incompetence \n and disreputable conduct. \nIncompetence and disreputable conduct for which \na practitioner may be sanctioned under §10.50 \nincludes, but is not limited to — \nTreasury Department Circular No. 230\nTable of Contents\n", "(1) Conviction of any criminal offense under the \nFederal tax laws. \n(2) Conviction of any criminal offense involving \ndishonesty or breach of trust. \n(3) Conviction of any felony under Federal or \nState law for which the conduct involved renders \nthe practitioner unfit to practice before the Internal \nRevenue Service. \n(4) Giving false or misleading information, or \nparticipating in any way in the giving of false or \nmisleading information to the Department of the \nTreasury or any officer or employee thereof, or to any \ntribunal authorized to pass upon Federal tax matters, \nin connection with any matter pending or likely to be \npending before them, knowing the information to be \nfalse or misleading. Facts or other matters contained \nin testimony, Federal tax returns, financial statements, \napplications for enrollment, affidavits, declarations, \nand any other document or statement, written or oral, \nare included in the term “information.” \n(5) Solicitation of employment as prohibited \nunder §10.30, the use of false or misleading \nrepresentations with intent to deceive a client or \nprospective client in order to procure employment, \nor intimating that the practitioner is able improperly \nto obtain special consideration or action from the \nInternal Revenue Service or any officer or employee \nthereof. \n(6) Willfully failing to make a Federal tax return \nin violation of the Federal tax laws, or willfully \nevading, attempting to evade, or participating in any \nway in evading or attempting to evade any assessment \nor payment of any Federal tax. \n(7) Willfully assisting, counseling, encouraging a \nclient or prospective client in violating, or suggesting \nto a client or prospective client to violate, any Federal \ntax law, or knowingly counseling or suggesting to a \nclient or prospective client an illegal plan to evade \nFederal taxes or payment thereof. \n(8) Misappropriation of, or failure properly or \npromptly to remit, funds received from a client for \nthe purpose of payment of taxes or other obligations \ndue the United States. \n(9) Directly or indirectly attempting to influence, \nor offering or agreeing to attempt to influence, the \nTreasury Department Circular No. 230\nofficial action of any officer or employee of the \nInternal Revenue Service by the use of threats, false \naccusations, duress or coercion, by the offer of any \nspecial inducement or promise of an advantage or by \nthe bestowing of any gift, favor or thing of value. \n(10) Disbarment or suspension from practice \nas an attorney, certified public accountant, public \naccountant, or actuary by any duly constituted \nauthority of any State, territory, or possession of the \nUnited States, including a Commonwealth, or the \nDistrict of Columbia, any Federal court of record or \nany Federal agency, body or board. \n(11) Knowingly aiding and abetting another \nperson to practice before the Internal Revenue \nService during a period of suspension, disbarment \nor ineligibility of such other person. \n(12) Contemptuous conduct in connection \nwith practice before the Internal Revenue Service, \nincluding the use of abusive language, making false \naccusations or statements, knowing them to be false, \nor circulating or publishing malicious or libelous \nmatter. \n(13) Giving a false opinion, knowingly, \nrecklessly, or through gross incompetence, including \nan opinion which is intentionally or recklessly \nmisleading, or engaging in a pattern of providing \nincompetent opinions on questions arising under the \nFederal tax laws. False opinions described in this \nparagraph (a)(l3) include those which reflect or result \nfrom a knowing misstatement of fact or law, from an \nassertion of a position known to be unwarranted under \nexisting law, from counseling or assisting in conduct \nknown to be illegal or fraudulent, from concealing \nmatters required by law to be revealed, or from \nconsciously disregarding information indicating that \nmaterial facts expressed in the opinion or offering \nmaterial are false or misleading. For purposes \nof this paragraph (a)(13), reckless conduct is a \nhighly unreasonable omission or misrepresentation \ninvolving an extreme departure from the standards \nof ordinary care that a practitioner should observe \nunder the circumstances. A pattern of conduct is a \nfactor that will be taken into account in determining \nwhether a practitioner acted knowingly, recklessly, \nor through gross incompetence. Gross incompetence \n§ 10.51 — Page 29 \nTable of Contents\n", " \n \nincludes conduct that reflects gross indifference, \npreparation which is grossly inadequate under the \ncircumstances, and a consistent failure to perform \nobligations to the client. \n(14) Willfully failing to sign a tax return \nprepared by the practitioner when the practitioner’s \nsignature is required by Federal tax laws unless the \nfailure is due to reasonable cause and not due to \nwillful neglect. \n(15) Willfully disclosing or otherwise using a \ntax return or tax return information in a manner not \nauthorized by the Internal Revenue Code, contrary \nto the order of a court of competent jurisdiction, or \ncontrary to the order of an administrative law judge \nin a proceeding instituted under §10.60. \n(16) Willfully failing to file on magnetic or \nother electronic media a tax return prepared by the \npractitioner when the practitioner is required to do \nso by the Federal tax laws unless the failure is due \nto reasonable cause and not due to willful neglect. \n(17) Willfully preparing all or substantially \nall of, or signing, a tax return or claim for refund \nwhen the practitioner does not possess a current or \notherwise valid preparer tax identification number \nor other prescribed identifying number. \n(18) Willfully representing a taxpayer before \nan officer or employee of the Internal Revenue \nService unless the practitioner is authorized to do so \npursuant to this part. \n(b) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.52 Violations subject to sanction. \n(a) A practitioner may be sanctioned under §10.50 \nif the practitioner — \n(1) Willfully violates any of the regulations (other \nthan §10.33) contained in this part; or \n(2) Recklessly or through gross incompetence \n(within the meaning of §10.51(a)(13)) violates §§ \n10.34, 10.35, 10.36 or 10.37. \n(b) Effective/applicability date. This section is \napplicable to conduct occurring on or after September \n26, 2007. \n§ 10.53 Receipt of information concerning \npractitioner. \n(a) Officer or employee of the Internal Revenue \nService. If an officer or employee of the Internal \nRevenue Service has reason to believe a practitioner \nhas violated any provision of this part, the officer \nor employee will promptly make a written report \nof the suspected violation. The report will explain \nthe facts and reasons upon which the officer’s or \nemployee’s belief rests and must be submitted \nto the office(s) of the Internal Revenue Service \nresponsible for administering or enforcing this part. \n(b) Other persons. Any person other than an \nofficer or employee of the Internal Revenue Service \nhaving information of a violation of any provision \nof this part may make an oral or written report of \nthe alleged violation to the office(s) of the Internal \nRevenue Service responsible for administering or \nenforcing this part or any officer or employee of \nthe Internal Revenue Service. If the report is made \nto an officer or employee of the Internal Revenue \nService, the officer or employee will make a \nwritten report of the suspected violation and submit \nthe report to the office(s) of the Internal Revenue \nService responsible for administering or enforcing \nthis part. \n(c) Destruction of report. No report made \nunder paragraph (a) or (b) of this section shall \nbe maintained unless retention of the report is \npermissible under the applicable records control \nschedule as approved by the National Archives \nand Records Administration and designated \nin the Internal Revenue Manual. Reports must \nbe destroyed as soon as permissible under the \napplicable records control schedule. \n(d) Effect on proceedings under subpart D. The \ndestruction of any report will not bar any proceeding \nunder subpart D of this part, but will preclude the \nuse of a copy of the report in a proceeding under \nsubpart D of this part. \n(e) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \nPage 30 — § 10.51 \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n \n \n \nSubpart D — Rules Applicable to Disciplinary \nProceedings \n§ 10.60 Institution of proceeding. \n(a) Whenever it is determined that a practitioner (or \nemployer, firm or other entity, if applicable) violated \nany provision of the laws governing practice before \nthe Internal Revenue Service or the regulations in \nthis part, the practitioner may be reprimanded or, in \naccordance with §10.62, subject to a proceeding for \nsanctions described in §10.50. \n(b) Whenever a penalty has been assessed against \nan appraiser under the Internal Revenue Code and an \nappropriate officer or employee in an office established \nto enforce this part determines that the appraiser acted \nwillfully, recklessly, or through gross incompetence \nwith respect to the proscribed conduct, the appraiser \nmay be reprimanded or, in accordance with §10.62, \nsubject to a proceeding for disqualification. \nA \nproceeding for disqualification of an appraiser is \ninstituted by the filing of a complaint, the contents of \nwhich are more fully described in §10.62. \n(c) Except as provided in §10.82, a proceeding \nwill not be instituted under this section unless the \nproposed respondent previously has been advised \nin writing of the law, facts and conduct warranting \nsuch action and has been accorded an opportunity \nto dispute facts, assert additional facts, and make \narguments (including an explanation or description \nof mitigating circumstances). \n(d) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \n§ 10.61 Conferences. \n(a) In general. \n The Commissioner, or delegate, \nmay confer with a practitioner, employer, firm or \nother entity, or an appraiser concerning allegations of \nmisconduct irrespective of whether a proceeding has \nbeen instituted. If the conference results in a stipulation \nin connection with an ongoing proceeding in which the \npractitioner, employer, firm or other entity, or appraiser \nis the respondent, the stipulation may be entered in the \nrecord by either party to the proceeding. \nTreasury Department Circular No. 230\n(b) Voluntary sanction — \n(1) In general. In lieu of a proceeding being \ninstituted or continued under §10.60(a), a practitioner \nor appraiser (or employer, firm or other entity, if \napplicable) may offer a consent to be sanctioned \nunder §10.50. \n(2) Discretion; acceptance or declination. The \nCommissioner, or delegate, may accept or decline \nthe offer described in paragraph (b)(1) of this \nsection. When the decision is to decline the offer, \nthe written notice of declination may state that the \noffer described in paragraph (b)(1) of this section \nwould be accepted if it contained different terms. \nThe Commissioner, or delegate, has the discretion to \naccept or reject a revised offer submitted in response \nto the declination or may counteroffer and act upon \nany accepted counteroffer. \n(c) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.62 Contents of complaint. \n(a) Charges. A complaint must name the \nrespondent, provide a clear and concise description \nof the facts and law that constitute the basis for \nthe proceeding, and be signed by an authorized \nrepresentative of the Internal Revenue Service \nunder §10.69(a)(1). A complaint is sufficient if \nit fairly informs the respondent of the charges \nbrought so that the respondent is able to prepare a \ndefense. \n(b) Specification of sanction. The complaint must \nspecify the sanction sought against the practitioner \nor appraiser. If the sanction sought is a suspension, \nthe duration of the suspension sought must be \nspecified. \n(c) Demand for answer. The respondent must \nbe notified in the complaint or in a separate paper \nattached to the complaint of the time for answering the \ncomplaint, which may not be less than 30 days from \nthe date of service of the complaint, the name and \naddress of the Administrative Law Judge with whom \nthe answer must be filed, the name and address of \nthe person representing the Internal Revenue Service \nto whom a copy of the answer must be served, and \n§ 10.62 — Page 31 \nTable of Contents\n", "that a decision by default may be rendered against \nthe respondent in the event an answer is not filed as \nrequired. \n(d) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.63 \n Service of complaint; service of other \n \npapers; service of evidence in support of \ncomplaint; filing of papers. \n(a) Service of complaint. \n(1) In general. \n The complaint or a copy of the \ncomplaint must be served on the respondent by any \nmanner described in paragraphs (a) (2) or (3) of this \nsection. \n(2) Service by certified or first class mail. \n \n(i) Service of the complaint may be made on \nthe respondent by mailing the complaint by certified \nmail to the last known address (as determined under \nsection 6212 of the Internal Revenue Code and the \nregulations thereunder) of the respondent. Where \nservice is by certified mail, the returned post office \nreceipt duly signed by the respondent will be proof \nof service. \n(ii) If the certified mail is not claimed \nor accepted by the respondent, or is returned \nundelivered, service may be made on the respondent, \nby mailing the complaint to the respondent by first \nclass mail. Service by this method will be considered \ncomplete upon mailing, provided the complaint is \naddressed to the respondent at the respondent’s last \nknown address as determined under section 6212 \nof the Internal Revenue Code and the regulations \nthereunder. \n(3) Service by other than certified or first class \nmail. \n(i) Service of the complaint may be made on \nthe respondent by delivery by a private delivery \nservice designated pursuant to section 7502(f) of the \nInternal Revenue Code to the last known address \n(as determined under section 6212 of the Internal \nRevenue Code and the regulations there under) of the \nrespondent. Service by this method will be considered \ncomplete, provided the complaint is addressed to the \nrespondent at the respondent’s last known address \nPage 32 — § 10.62 \nas determined under section 6212 of the Internal \nRevenue Code and the regulations thereunder. \n(ii) Service of the complaint may be made in \nperson on, or by leaving the complaint at the office \nor place of business of, the respondent. Service by \nthis method will be considered complete and proof \nof service will be a written statement, sworn or \naffirmed by the person who served the complaint, \nidentifying the manner of service, including the \nrecipient, relationship of recipient to respondent, \nplace, date and time of service. \n(iii) Service may be made by any other means \nagreed to by the respondent. Proof of service will be \na written statement, sworn or affirmed by the person \nwho served the complaint, identifying the manner \nof service, including the recipient, relationship \nof recipient to respondent, place, date and time of \nservice. \n(4) For purposes of this section, respondent \n \nmeans the practitioner, employer, firm or other entity, \nor appraiser named in the complaint or any other \nperson having the authority to accept mail on behalf \nof the practitioner, employer, firm or other entity or \nappraiser. \n(b) Service of papers other than complaint. \n Any \npaper other than the complaint may be served on the \nrespondent, or his or her authorized representative \nunder §10.69(a)(2) by: \n(1) mailing the paper by first class mail to the last \nknown address (as determined under section 6212 \nof the Internal Revenue Code and the regulations \nthereunder) of the respondent or the respondent’s \nauthorized representative, \n(2) delivery by a private delivery service \ndesignated pursuant to section 7502(f) of the \nInternal Revenue Code to the last known address \n(as determined under section 6212 of the Internal \nRevenue Code and the regulations thereunder) \nof the respondent or the respondent’s authorized \nrepresentative, or \n(3) as provided in paragraphs (a)(3)(ii) and (a)(3) \n(iii) of this section. \n(c) Service \n of papers on the Internal Revenue \nService. \n Whenever a paper is required or permitted \nto be served on the Internal Revenue Service in \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n \n \n \nconnection with a proceeding under this part, \nthe paper will be served on the Internal Revenue \nService’s authorized representative under §10.69(a) \n(1) at the address designated in the complaint, or at \nan address provided in a notice of appearance. If no \naddress is designated in the complaint or provided \nin a notice of appearance, service will be made on \nthe office(s) established to enforce this part under the \nauthority of §10.1, Internal Revenue Service, 1111 \nConstitution Avenue, NW, Washington, DC 20224. \n(d) Service \n of evidence in support of complaint. \nWithin 10 days of serving the complaint, copies of \nthe evidence in support of the complaint must be \nserved on the respondent in any manner described in \nparagraphs (a)(2) and (3) of this section. \n(e) Filing of papers. Whenever the filing of a \npaper is required or permitted in connection with \na proceeding under this part, the original paper, \nplus one additional copy, must be filed with the \nAdministrative Law Judge at the address specified \nin the complaint or at an address otherwise specified \nby the Administrative Law Judge. All papers \nfiled in connection with a proceeding under this \npart must be served on the other party, unless the \nAdministrative Law Judge directs otherwise. A \ncertificate evidencing such must be attached to the \noriginal paper filed with the Administrative Law \nJudge. \n(f) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.64 Answer; default. \n(a) Filing. The respondent’s answer must be filed \nwith the Administrative Law Judge, and served \non the Internal Revenue Service, within the time \nspecified in the complaint unless, on request or \napplication of the respondent, the time is extended \nby the Administrative Law Judge. \n(b) Contents. The answer must be written and \ncontain a statement of facts that constitute the \nrespondent’s grounds of defense. General denials \nare not permitted. The respondent must specifically \nadmit or deny each allegation set forth in the \ncomplaint, except that the respondent may state that \nTreasury Department Circular No. 230\nthe respondent is without sufficient information to \nadmit or deny a specific allegation. The respondent, \nnevertheless, may not deny a material allegation in \nthe complaint that the respondent knows to be true, \nor state that the respondent is without sufficient \ninformation to form a belief, when the respondent \npossesses the required information. The respondent \nalso must state affirmatively any special matters of \ndefense on which he or she relies. \n(c) Failure to deny or answer allegations in the \ncomplaint. Every allegation in the complaint that is \nnot denied in the answer is deemed admitted and will \nbe considered proved; no further evidence in respect \nof such allegation need be adduced at a hearing. \n(d) Default. Failure to file an answer within the time \nprescribed (or within the time for answer as extended \nby the Administrative Law Judge), constitutes an \nadmission of the allegations of the complaint and \na waiver of hearing, and the Administrative Law \nJudge may make the decision by default without a \nhearing or further procedure. A decision by default \nconstitutes a decision under §10.76. \n(e) Signature. The answer must be signed by \nthe respondent or the respondent’s authorized \nrepresentative \nunder \n§10.69(a)(2) \nand \nmust \ninclude a statement directly above the signature \nacknowledging that the statements made in the \nanswer are true and correct and that knowing and \nwillful false statements may be punishable under 18 \nU.S.C. §1001. \n(f) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \n§ 10.65 Supplemental charges. \n(a) In general. Supplemental charges may be filed \nagainst the respondent by amending the complaint \nwith the permission of the Administrative Law Judge \nif, for example — \n(1) It appears that the respondent, in the answer, \nfalsely and in bad faith, denies a material allegation \nof fact in the complaint or states that the respondent \nhas insufficient knowledge to form a belief, when the \nrespondent possesses such information; or \n(2) It appears that the respondent has knowingly \n§ 10.65 — Page 33 \nTable of Contents\n", " \n \n \n \n \n \n \nintroduced false testimony during the proceedings \nagainst the respondent. \n(b) Hearing. The supplemental charges may be \nheard with other charges in the case, provided the \nrespondent is given due notice of the charges and \nis afforded a reasonable opportunity to prepare a \ndefense to the supplemental charges. \n(c) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.66 Reply to answer. \n(a) The Internal Revenue Service may file a reply \nto the respondent’s answer, but unless otherwise \nordered by the Administrative Law Judge, no reply \nto the respondent’s answer is required. If a reply is \nnot filed, new matter in the answer is deemed denied. \n(b) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \n§ 10.67 Proof; variance; amendment of pleadings. \nIn the case of a variance between the allegations in \npleadings and the evidence adduced in support of the \npleadings, the Administrative Law Judge, at any time \nbefore decision, may order or authorize amendment \nof the pleadings to conform to the evidence. The \nparty who would otherwise be prejudiced by the \namendment must be given a reasonable opportunity \nto address the allegations of the pleadings as amended \nand the Administrative Law Judge must make \nfindings on any issue presented by the pleadings as \namended. \n§ 10.68 Motions and requests. \n(a) Motions — \n(1) In general. At any time after the filing of \nthe complaint, any party may file a motion with the \nAdministrative Law Judge. Unless otherwise ordered \nby the Administrative Law Judge, motions must be \nin writing and must be served on the opposing party \nas provided in §10.63(b). A motion must concisely \nspecify its grounds and the relief sought, and, if \nappropriate, must contain a memorandum of facts \nand law in support. \nPage 34 — § 10.65 \n(2) Summary adjudication. Either party may \nmove for a summary adjudication upon all or any \npart of the legal issues in controversy. If the non-\nmoving party opposes summary adjudication in the \nmoving party’s favor, the non-moving party must \nfile a written response within 30 days unless ordered \notherwise by the Administrative Law Judge. \n(3) Good Faith. A party filing a motion for \nextension of time, a motion for postponement of a \nhearing, or any other non-dispositive or procedural \nmotion must first contact the other party to determine \nwhether there is any objection to the motion, and \nmust state in the motion whether the other party has \nan objection. \n(b) Response. Unless otherwise ordered by the \nAdministrative Law Judge, the nonmoving party \nis not required to file a response to a motion. If \nthe Administrative Law Judge does not order \nthe nonmoving party to file a response, and the \nnonmoving party files no response, the nonmoving \nparty is deemed to oppose the motion. If a nonmoving \nparty does not respond within 30 days of the filing \nof a motion for decision by default for failure to \nfile a timely answer or for failure to prosecute, the \nnonmoving party is deemed not to oppose the motion. \n(c) Oral motions; oral argument — \n(1) The Administrative Law Judge may, for good \ncause and with notice to the parties, permit oral \nmotions and oral opposition to motions. \n(2) The Administrative Law Judge may, within \nhis or her discretion, permit oral argument on any \nmotion. \n(d) Orders. \n The Administrative Law Judge should \nissue written orders disposing of any motion or \nrequest and any response thereto. \n(e) Effective/applicability date. \n This section is \napplicable on September 26, 2007. \n§ 10.69 Representation; ex parte communication. \n(a) Representation. \n(1) The Internal Revenue Service may be \nrepresented in proceedings under this part by an \nattorney or other employee of the Internal Revenue \nService. An attorney or an employee of the Internal \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n \nRevenue Service representing the Internal Revenue \nService in a proceeding under this part may sign the \ncomplaint or any document required to be filed in \nthe proceeding on behalf of the Internal Revenue \nService. \n(2) A respondent may appear in person, be \nrepresented by a practitioner, or be represented by \nan attorney who has not filed a declaration with \nthe Internal Revenue Service pursuant to §10.3. A \npractitioner or an attorney representing a respondent \nor proposed respondent may sign the answer or any \ndocument required to be filed in the proceeding on \nbehalf of the respondent. \n(b) Ex parte communication. The Internal Revenue \nService, the respondent, and any representatives of \neither party, may not attempt to initiate or participate \nin ex parte discussions concerning a proceeding or \npotential proceeding with the Administrative Law \nJudge (or any person who is likely to advise the \nAdministrative Law Judge on a ruling or decision) \nin the proceeding before or during the pendency \nof the proceeding. Any memorandum, letter or \nother communication concerning the merits of the \nproceeding, addressed to the Administrative Law \nJudge, by or on behalf of any party shall be regarded \nas an argument in the proceeding and shall be served \non the othe party.\n (c) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \n§ 10.70 Administrative Law Judge. \n(a) Appointment. Proceedings on complaints for the \nsanction (as described in §10.50) of a practitioner, \nemployer, firm or other entity, or appraiser will be \nconducted by an Administrative Law Judge appointed \nas provided by 5 U.S.C. 3105. \n(b) Powers of the Administrative Law Judge. The \nAdministrative Law Judge, among other powers, \nhas the authority, in connection with any proceeding \nunder §10.60 assigned or referred to him or her, to do \nthe following: \n(1) Administer oaths and affirmations; \n(2) Make rulings on motions and requests, which \nrulings may not be appealed prior to the close of a \nTreasury Department Circular No. 230\nhearing except in extraordinary circumstances and at \nthe discretion of the Administrative Law Judge; \n(3) Determine the time and place of hearing and \nregulate its course and conduct; \n(4) Adopt rules of procedure and modify the \nsame from time to time as needed for the orderly \ndisposition of proceedings; \n(5) Rule on offers of proof, receive relevant \nevidence, and examine witnesses; \n(6) Take or authorize the taking of depositions or \nanswers to requests for admission; \n(7) Receive and consider oral or written argument \non facts or law; \n(8) Hold or provide for the holding of conferences \nfor the settlement or simplification of the issues with \nthe consent of the parties; \n(9) Perform such acts and take such measures as \nare necessary or appropriate to the efficient conduct \nof any proceeding; and \n(10) Make decisions. \n(c) Effective/applicability date. \n This section is \napplicable on September 26, 2007. \n§ 10.71 Discovery. \n(a) In general. Discovery may be permitted, at the \ndiscretion of the Administrative Law Judge, only \nupon written motion demonstrating the relevance, \nmateriality and reasonableness of the requested \ndiscovery and subject to the requirements of \n§10.72(d)(2) and (3). Within 10 days of receipt of \nthe answer, the Administrative Law Judge will notify \nthe parties of the right to request discovery and the \ntimeframe for filing a request. Arequest for discovery, \nand objections, must be filed in accordance with \n§10.68. In response to a request for discovery, the \nAdministrative Law Judge may order — \n(1) Depositions upon oral examination; or \n(2) Answers to requests for admission. \n(b) Depositions upon oral examination — \n(1) A \n deposition must be taken before an officer \nduly authorized to administer an oath for general \npurposes or before an officer or employee of the \nInternal Revenue Service who is authorized to \nadminister an oath in Federal tax law matters. \n§ 10.71 — Page 35 \nTable of Contents\n", " \n \n \n(2) In ordering a deposition, the Administrative \nLaw Judge will require reasonable notice to the \nopposing party as to the time and place of the \ndeposition. The opposing party, if attending, will be \nprovided the opportunity for full examination and \ncross-examination of any witness. \n(3) Expenses in the reporting of depositions \nshall be borne by the party at whose instance \nthe deposition is taken. Travel expenses of the \ndeponent shall be borne by the party requesting the \ndeposition, unless otherwise authorized by Federal \nlaw or regulation. \n(c) Requests for admission. Any party may serve \non any other party a written request for admission of \nthe truth of any matters which are not privileged and \nare relevant to the subject matter of this proceeding. \nRequests for admission shall not exceed a total of 30 \n(including any subparts within a specific request) \nwithout the approval from the Administrative Law \nJudge. \n(d) Limitations. Discovery shall not be authorized if — \n(1) The request fails to meet any requirement set \nforth in paragraph (a) of this section; \n(2) It will unduly delay the proceeding; \n(3) It will place an undue burden on the party \nrequired to produce the discovery sought; \n(4) It is frivolous or abusive; \n(5) It is cumulative or duplicative; \n(6) The material sought is privileged or otherwise \nprotected from disclosure by law; \n(7) The material sought relates to mental \nimpressions, conclusions, of legal theories of any \nparty, attorney, or other representative, or a party \nprepared in the anticipation of a proceeding; or \n(8) The material sought is available generally \nto the public, \n equally to the parties, or to the party \nseeking the discovery through another source. \n(e) Failure to comply. \n Where a party fails to comply \nwith an order of the Administrative Law Judge under \nthis section, the Administrative Law Judge may, among \nother things, infer that the information would be adverse \nto the party failing to provide it, exclude the information \nfrom evidence or issue a decision by default. \n(f) Other discovery. No discovery other than that \nspecifically provided for in this section is permitted. \nPage 36 — § 10.71 \n(g) Effective/applicability date. This section \nis applicable to proceedings initiated on or after \nSeptember 26, 2007. \n§ 10.72 Hearings. \n(a) In general — \n(1) Presiding officer. An Administrative Law \nJudge will preside at the hearing on a complaint \nfiled under §10.60 for the sanction of a practitioner, \nemployer, firm or other entity, or appraiser. \n(2) Time for hearing. Absent a determination by \nthe Administrative Law Judge that, in the interest \nof justice, a hearing must be held at a later time, \nthe Administrative Law Judge should, on notice \nsufficient to allow proper preparation, schedule the \nhearing to occur no later than 180 days after the time \nfor filing the answer. \n(3) Procedural requirements. \n \n(i) Hearings will be stenographically recorded \nand transcribed and the testimony of witnesses will \nbe taken under oath or affirmation. \n(ii) Hearings will be conducted pursuant to \n \n5 U.S.C. 556. \n(iii) A hearing in a proceeding requested under \n§10.82(g) will be conducted de novo. \n(iv) An evidentiary hearing must be held in all \nproceedings prior to the issuance of a decision by the \nAdministrative Law Judge unless — \n(A) The Internal Revenue Service withdraws \nthe complaint; \n(B) A decision is issued by default pursuant to \n§10.64(d); \n(C) A decision is issued under §10.82 (e); \n(D) The respondent requests a decision on the \nwritten record without a hearing; or \n(E) The Administrative Law Judge issues a \ndecision under §10.68(d) or rules on another motion \nthat disposes of the case prior to the hearing. \n(b) Cross-examination. A party is entitled to present \nhis or her case or defense by oral or documentary \nevidence, to submit rebuttal evidence, and to \nconduct cross-examination, in the presence of the \nAdministrative Law Judge, as may be required \nfor a full and true disclosure of the facts. This \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n \n \n \n \n \n \n \n \n \nparagraph (b) does not limit a party from presenting \nevidence contained within a deposition when the \nAdministrative Law Judge determines that the \ndeposition has been obtained in compliance with the \nrules of this subpart D. \n(c) Prehearing memorandum. Unless otherwise \nordered by the Administrative Law Judge, each party \nshall file, and serve on the opposing party or the \nopposing party’s representative, prior to any hearing, \na prehearing memorandum containing — \n(1) A list (together with a copy) of all proposed \nexhibits to be used in the party’s case in chief; \n(2) A list of proposed witnesses, including a \nsynopsis of their expected testimony, or a statement \nthat no witnesses will be called; \n(3) Identification of any proposed expert \nwitnesses, including a synopsis of their expected \ntestimony and a copy of any report prepared by the \nexpert or at his or her direction; and \n(4) A list of undisputed facts. \n(d) Publicity — \n(1) In general. All reports and decisions of the \nSecretary of the Treasury, or delegate, including \nany reports and decisions of the Administrative \nLaw Judge, under this subpart D are, subject to \nthe protective measures in paragraph (d)(4) of this \nsection, public and open to inspection within 30 \ndays after the agency’s decision becomes final. \n(2) Request for additional publicity. The \nAdministrative Law Judge may grant a request by \na practitioner or appraiser that all the pleadings and \nevidence of the disciplinary proceeding be made \navailable for inspection where the parties stipulate \nin advance to adopt the protective measures in \nparagraph (d)(4) of this section. \n(3) Returns and return information — \n(i) Disclosure to practitioner or appraiser. \n \nPursuant to section 6103(l)(4) of the Internal \nRevenue Code, the Secretary of the Treasury, \nor delegate, may disclose returns and return \ninformation to any practitioner or appraiser, or to \nthe authorized representative of the practitioner \nor appraiser, whose rights are or may be affected \nby an administrative action or proceeding under \nthis subpart D, but solely for use in the action or \nTreasury Department Circular No. 230\nproceeding and only to the extent that the Secretary \nof the Treasury, or delegate, determines that the \nreturns or return information are or may be relevant \nand material to the action or proceeding. \n(ii) Disclosure to officers and employees of \nthe Department of the Treasury. Pursuant to section \n6103(l)(4)(B) of the Internal Revenue Code the \nSecretary of the Treasury, or delegate, may disclose \nreturns and return information to officers and \nemployees of the Department of the Treasury for \nuse in any action or proceeding under this subpart \nD, to the extent necessary to advance or protect the \ninterests of the United States. \n(iii) Use of returns and return information. \n \nRecipients of returns and return information under \nthis paragraph (d)(3) may use the returns or return \ninformation solely in the action or proceeding, or \nin preparation for the action or proceeding, with \nrespect to which the disclosure was made. \n(iv) Procedures for disclosure of returns and \nreturn information. \n When providing returns or \nreturn information to the practitioner or appraiser, \nor authorized representative, the Secretary of the \nTreasury, or delegate, will — \n(A) Redact identifying information of any \nthird party taxpayers and replace it with a code; \n(B) Provide a key to the coded information; \nand \n(C) Notify the practitioner or appraiser, or \nauthorized representative, of the restrictions on \nthe use and disclosure of the returns and return \ninformation, the applicable damages remedy \nunder section 7431 of the Internal Revenue Code, \nand that unauthorized disclosure of information \nprovided by the Internal Revenue Service under \nthis paragraph (d)(3) is also a violation of this part. \n(4) Protective measures — \n(i) Mandatory protection order. If redaction of \nnames, addresses, and other identifying information \nof third party taxpayers may still permit indirect \nidentification of any third party taxpayer, the \nAdministrative Law Judge will issue a protective \norder to ensure that the identifying information is \navailable to the parties and the Administrative Law \nJudge for purposes of the proceeding, but is not \n§ 10.72 — Page 37 \nTable of Contents\n", " \n(1) That disclosure of information be made \nonly on specified terms and conditions, including a \ndesignation of the time or place; \n \n(2) That a trade secret or other information \nnot be disclosed, or be disclosed only in a designated \nway. \n \n \n \ndisclosed to, or open to inspection by, the public. \n(ii) Authorized orders. \n \n(A) Upon motion by a party or any other \naffected person, and for good cause shown, the \nAdministrative Law Judge may make any order \nwhich justice requires to protect any person in the \nevent disclosure of information is prohibited by law, \nprivileged, confidential, or sensitive in some other \nway, including, but not limited to, one or more of \nthe following — \n(iii) Denials. If a motion for a protective order \nis denied in whole or in part, the Administrative \nLaw Judge may, on such terms or conditions as \nthe Administrative Law Judge deems just, order \nany party or person to comply with, or respond in \naccordance with, the procedure involved. \n(iv) Public inspection of documents. The \nSecretary of the Treasury, or delegate, shall ensure \nthat all names, addresses or other identifying details \nof third party taxpayers are redacted and replaced \nwith the code assigned to the corresponding taxpayer \nin all documents prior to public inspection of such \ndocuments. \n(e) Location. \n The location of the hearing will be \ndetermined by the agreement of the parties with the \napproval of the Administrative Law Judge, but, in \nthe absence of such agreement and approval, the \nhearing will be held in Washington, D.C. \n(f) Failure to appear. \n If either party to the \nproceeding fails to appear at the hearing, after \nnotice of the proceeding has been sent to him or her, \nthe party will be deemed to have waived the right \nto a hearing and the Administrative Law Judge may \nmake his or her decision against the absent party by \ndefault. \n(g) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \nPage 38 — § 10.72 \n§ 10.73 Evidence. \n(a) In general. \n The rules of evidence prevailing \nin courts of law and equity are not controlling in \nhearings or proceedings conducted under this part. \nThe Administrative Law Judge may, however, \nexclude evidence that is irrelevant, immaterial, or \nunduly repetitious. \n(b) Depositions. \n The deposition of any witness \ntaken pursuant to §10.71 may be admitted into \nevidence in any proceeding instituted under §10.60. \n(c) Requests for admission. Any matter admitted \nin response to a request for admission under \n§10.71 is conclusively established unless the \nAdministrative Law Judge on motion permits \nwithdrawal or modification of the admission. Any \nadmission made by a party is for the purposes of \nthe pending action only and is not an admission by \na party for any other purpose, nor may it be used \nagainst a party in any other proceeding. \n(d) Proof of documents. Official documents, \nrecords, and papers of the Internal Revenue Service \nand the Office of Professional Responsibility are \nadmissible in evidence without the production of \nan officer or employee to authenticate them. Any \ndocuments, records, and papers may be evidenced \nby a copy attested to or identified by an officer or \nemployee of the Internal Revenue Service or the \nTreasury Department, as the case may be. \n(e) Withdrawal of exhibits. If any document, \nrecord, or other paper is introduced in evidence \nas an exhibit, the Administrative Law Judge may \nauthorize the withdrawal of the exhibit subject to \nany conditions that he or she deems proper. \n(f) Objections. Objections to evidence are to be \nmade in short form, stating the grounds for the \nobjection. Except as ordered by the Administrative \nLaw Judge, argument on objections will not be \nrecorded or transcribed. Rulings on objections \nare to be a part of the record, but no exception to \na ruling is necessary to preserve the rights of the \nparties. \n(g) Effective/applicability date. \n This section is \napplicable on September 26, 2007. \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n \n \n \n§ 10.74 Transcript. \nIn cases where the hearing is stenographically \nreported by a Government contract reporter, copies \nof the transcript may be obtained from the reporter \nat rates not to exceed the maximum rates fixed by \ncontract between the Government and the reporter. \nWhere the hearing is stenographically reported by a \nregular employee of the Internal Revenue Service, \na copy will be supplied to the respondent either \nwithout charge or upon the payment of a reasonable \nfee. Copies of exhibits introduced at the hearing or \nat the taking of depositions will be supplied to the \nparties upon the payment of a reasonable fee (Sec. \n501, Public Law 82-137) (65 Stat. 290) (31 U.S.C. \n§ 483a). \n§ 10.75 Proposed findings and conclusions. \nExcept in cases where the respondent has failed to \nanswer the complaint or where a party has failed to \nappear at the hearing, the parties must be afforded a \nreasonable opportunity to submit proposed findings \nand conclusions and their supporting reasons to the \nAdministrative Law Judge. \n§ 10.76 Decision of Administrative Law Judge. \n(a) In general — \n(1) Hearings. Within 180 days after the \nconclusion of a hearing and the receipt of any \nproposed \nfindings \nand \nconclusions \ntimely \nsubmitted by the parties, the Administrative Law \nJudge should enter a decision in the case. The \ndecision must include a statement of findings \nand conclusions, as well as the reasons or basis \nfor making such findings and conclusions, and \nan order of censure, suspension, disbarment, \nmonetary penalty, disqualification, or dismissal of \nthe complaint. \n(2) Summary adjudication. In the event that \na motion for summary adjudication is filed, the \nAdministrative Law Judge should rule on the \nmotion for summary adjudication within 60 \ndays after the party in opposition files a written \nresponse, or if no written response is filed, within \n90 days after the motion for summary adjudication \nis filed. A \n decision shall thereafter be rendered if \nthe pleadings, depositions, admissions, and any \nother admissible evidence show that there is no \ngenuine issue of material fact and that a decision \nmay be rendered as a matter of law. The decision \nmust include a statement of conclusions, as well as \nthe reasons or basis for making such conclusions, \nand an order of censure, suspension, disbarment, \nmonetary penalty, disqualification, or dismissal of \nthe complaint. \n(3) Returns and return information. \n In the \ndecision, the Administrative Law Judge should \nuse the code assigned to third party taxpayers \n(described in §10.72(d)). \n(b) Standard of proof. If the sanction is censure or \na suspension of less than six months’ duration, the \nAdministrative Law Judge, in rendering findings \nand conclusions, will consider an allegation of fact \nto be proven if it is established by the party who is \nalleging the fact by a preponderance of the evidence \nin the record. If the sanction is a monetary penalty, \ndisbarment or a suspension of six months or longer \nduration, an allegation of fact that is necessary for \na finding against the practitioner must be proven \nby clear and convincing evidence in the record. \nAn allegation of fact that is necessary for a finding \nof disqualification against an appraiser must be \nproved by clear and convincing evidence in the \nrecord. \n(c) Copy of decision. The Administrative Law \nJudge will provide the decision to the Internal \nRevenue Service’s authorized representative, and \na copy of the decision to the respondent or the \nrespondent’s authorized representative. \n(d) When final. In the absence of an appeal to the \nSecretary of the Treasury or delegate, the decision \nof the Administrative Law Judge will, without \nfurther proceedings, become the decision of the \nagency 30 days after the date of the Administrative \nLaw Judge’s decision. \n(e) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \nTreasury Department Circular No. 230\n§ 10.76 — Page 39 \nTable of Contents\n", " \n \n \n \n \n \n§ 10.77 Appeal of decision of Administrative Law \nJudge. \n(a) Appeal. Any party to the proceeding under \nthis subpart D may appeal the decision of the \nAdministrative Law Judge by filing a notice of \nappeal with the Secretary of the Treasury, or delegate \ndeciding appeals. The notice of appeal must include \na brief that states exceptions to the decision of \nAdministrative Law Judge and supporting reasons \nfor such exceptions. \n(b) Time and place for filing of appeal. The notice \nof appeal and brief must be filed, in duplicate, with \nthe Secretary of the Treasury, or delegate deciding \nappeals, at an address for appeals that is identified \nto the parties with the decision of the Administrative \nLaw Judge. The notice of appeal and brief must be \nfiled within 30 days of the date that the decision \nof the Administrative Law Judge is served on the \nparties. The appealing party must serve a copy \nof the notice of appeal and the brief to any non \nappealing party or, if the party is represented, the \nnon-appealing party’s representative. \n(c) Response. Within 30 days of receiving the \ncopy of the appellant’s brief, the other party \nmay file a response brief with the Secretary of \nthe Treasury, or delegate deciding appeals, using \nthe address identified for appeals. A copy of the \nresponse brief must be served at the same time on \nthe opposing party or, if the party is represented, \nthe opposing party’s representative. \n(d) No other briefs, responses or motions as of \nright. Other than the appeal brief and response \nbrief, the parties are not permitted to file any other \nbriefs, responses or motions, except on a grant of \nleave to do so after a motion demonstrating sufficient \ncause, or unless otherwise ordered by the Secretary \nof the Treasury, or delegate deciding appeals. \n(e) Additional time for briefs and responses. \nNotwithstanding the time for filing briefs and \nresponses provided in paragraphs (b) and (c) of this \nsection, the Secretary of the Treasury, or delegate \ndeciding appeals, may, for good cause, authorize \nadditional time for filing briefs and responses \nupon a motion of a party or upon the initiative of \nPage 40 — § 10.77 \nthe Secretary of the Treasury, or delegate deciding \nappeals. \n(f) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \n§ 10.78 Decision on review. \n(a) Decision on review. On appeal from or review \nof the decision of the Administrative Law Judge, the \nSecretary of the Treasury, or delegate, will make the \nagency decision. The Secretary of the Treasury, or \ndelegate, should make the agency decision within \n180 days after receipt of the appeal \n(b) Standard of review. \n The decision of the \nAdministrative Law Judge will not be reversed unless \nthe appellant establishes that the decision is clearly \nerroneous in light of the evidence in the record and \napplicable law. Issues that are exclusively matters of \nlaw will be reviewed de novo. In the event that the \nSecretary of the Treasury, or delegate, determines \nthat there are unresolved issues raised by the record, \nthe case may be remanded to the Administrative Law \nJudge to elicit additional testimony or evidence. \n(c) Copy of decision on review. The Secretary of \nthe Treasury, or delegate, will provide copies of the \nagency decision to the authorized representative of \nthe Internal Revenue Service and the respondent or \nthe respondent’s authorized representative. \n(d) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.79 Effect of disbarment, suspension, or censure. \n(a) Disbarment. When the final decision in a case \nis against the respondent (or the respondent has \noffered his or her consent and such consent has been \naccepted by the Internal Revenue Service) and such \ndecision is for disbarment, the respondent will not \nbe permitted to practice before the Internal Revenue \nService unless and until authorized to do so by the \nInternal Revenue Service pursuant to §10.81. \n(b) Suspension. When the final decision in a case \nis against the respondent (or the respondent has \noffered his or her consent and such consent has \nbeen accepted by the Internal Revenue Service) \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n \n \nand such decision is for suspension, the respondent \nwill not be permitted to practice before the Internal \nRevenue Service during the period of suspension. \nFor periods after the suspension, the practitioner’s \nfuture representations may be subject to conditions \nas authorized by paragraph (d) of this section. \n(c) Censure. When the final decision in the case \nis against the respondent (or the Internal Revenue \nService has accepted the respondent’s offer to \nconsent, if such offer was made) and such decision \nis for censure, the respondent will be permitted to \npractice before the Internal Revenue Service, but the \nrespondent’s future representations may be subject \nto conditions as authorized by paragraph (d) of this \nsection. \n(d) Conditions. After being subject to the \nsanction of either suspension or censure, the future \nrepresentations of a practitioner so sanctioned \nshall be subject to specified conditions designed \nto promote high standards of conduct. These \nconditions can be imposed for a reasonable \nperiod in light of the gravity of the practitioner’s \nviolations. For example, where a practitioner is \ncensured because the practitioner failed to advise \nthe practitioner’s clients about a potential conflict \nof interest or failed to obtain the clients’ written \nconsents, the practitioner may be required to \nprovide the Internal Revenue Service with a copy \nof all consents obtained by the practitioner for an \nappropriate period following censure, whether or \nnot such consents are specifically requested. \n(e) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \n§ 10.80 Notice of disbarment, suspension, censure, \nor disqualification. \n(a) In general. On the issuance of a final order \ncensuring, suspending, or disbarring a practitioner or \na final order disqualifying an appraiser, notification \nof \nthe \ncensure, \nsuspension, \ndisbarment \nor \ndisqualification will be given to appropriate officers \nand employees of the Internal Revenue Service and \ninterested departments and agencies of the Federal \ngovernment. The Internal Revenue Service may \nTreasury Department Circular No. 230\ndetermine the manner of giving notice to the proper \nauthorities of the State by which the censured, \nsuspended, or disbarred person was licensed to \npractice. \n(b) Effective/applicability date. This section is \napplicable beginning August 2, 2011. \n§ 10.81 Petition for reinstatement. \n(a) In general. A practitioner disbarred or \nsuspended under §10.60, or suspended under \n§10.82, or a disqualified appraiser may petition \nfor reinstatement before the Internal Revenue \nService after the expiration of 5 years following \nsuch disbarment, suspension, or disqualification \n(or immediately following the expiration of the \nsuspension or disqualification period, if shorter than \n5 years). Reinstatement will not be granted unless \nthe Internal Revenue Service is satisfied that the \npetitioner is not likely to engage thereafter in conduct \ncontrary to the regulations in this part, and that \ngranting such reinstatement would not be contrary to \nthe public interest. \n(b) Effective/applicability date. This section is \napplicable beginning June 12, 2014. \n§ 10.82 Expedited suspension. \n(a) When applicable. Whenever the Commissioner, \nor delegate, determines that a practitioner is \ndescribed in paragraph (b) of this section, the \nexpedited procedures described in this section may \nbe used to suspend the practitioner from practice \nbefore the Internal Revenue Service. \n(b) To whom applicable. This section applies to \nany practitioner who, within 5 years prior to the \ndate that a show cause order under this section’s \nexpedited suspension procedures is served: \n(1) Has had a license to practice as an attorney, \ncertified public accountant, or actuary suspended or \nrevoked for cause (not including a failure to pay a \nprofessional licensing fee) by any authority or court, \nagency, body, or board described in §10.51(a)(10). \n(2) Has, irrespective of whether an appeal has \nbeen taken, been convicted of any crime under title \n§ 10.82 — Page 41 \nTable of Contents\n", "26 of the United States Code, any crime involving \ndishonesty or breach of trust, or any felony for which \nthe conduct involved renders the practitioner unfit \nto practice before the Internal Revenue Service. \n(3) Has violated conditions imposed on the \npractitioner pursuant to §10.79(d). \n(4) Has been sanctioned by a court of competent \njurisdiction, whether in a civil or criminal \nproceeding (including suits for injunctive relief), \nrelating to any taxpayer’s tax liability or relating to \nthe practitioner’s own tax liability, for — \n(i) Instituting or maintaining proceedings \nprimarily for delay; \n(ii) Advancing \nfrivolous \nor \ngroundless \narguments; or \n(iii) Failing to pursue available administrative \nremedies. \n(5) Has demonstrated a pattern of willful \ndisreputable conduct by— \n(i) Failing to make an annual Federal tax return, \nin violation of the Federal tax laws, during 4 of the \n5 tax years immediately preceding the institution of \na proceeding under paragraph (c) of this section and \nremains noncompliant with any of the practitioner’s \nFederal tax filing obligations at the time the notice \nof suspension is issued under paragraph (f) of this \nsection; or \n(ii) Failing to make a return required more \nfrequently than annually, in violation of the \nFederal tax laws, during 5 of the 7 tax periods \nimmediately \npreceding \nthe \ninstitution \nof \na \nproceeding under paragraph (c) of this section and \nremains noncompliant with any of the practitioner’s \nFederal tax filing obligations at the time the notice \nof suspension is issued under paragraph (f) of this \nsection. \n(c) Expedited suspension procedures. A suspension \nunder this section will be proposed by a show cause \norder that names the respondent, is signed by an \nauthorized representative of the Internal Revenue \nService under §10.69(a)(1), and served according \nto the rules set forth in §10.63(a). The show cause \norder must give a plain and concise description \nof the allegations that constitute the basis for the \nproposed suspension. The show cause order must \nnotify the respondent — \nPage 42 — § 10.82 \n(1) Of the place and due date for filing a \nresponse; \n(2) That an expedited suspension decision by \ndefault may be rendered if the respondent fails to \nfile a response as required; \n(3) That the respondent may request a conference \nto address the merits of the show cause order and \nthat any such request must be made in the response; \nand \n(4) That the respondent may be suspended \neither immediately following the expiration of the \nperiod within which a response must be filed or, if a \nconference is requested, immediately following the \nconference. \n(d) Response. The response to the show cause order \ndescribed in this section must be filed no later than \n30 calendar days following the date the show cause \norder is served, unless the time for filing is extended. \nThe response must be filed in accordance with the \nrules set forth for answers to a complaint in §10.64, \nexcept as otherwise provided in this section. The \nresponse must include a request for a conference, if \na conference is desired. The respondent is entitled \nto the conference only if the request is made in a \ntimely filed response. \n(e) Conference. An authorized representative \nof the Internal Revenue Service will preside \nat a conference described in this section. The \nconference will be held at a place and time selected \nby the Internal Revenue Service, but no sooner \nthan 14 calendar days after the date by which the \nresponse must be filed with the Internal Revenue \nService, unless the respondent agrees to an earlier \ndate. An authorized representative may represent \nthe respondent at the conference. \n(f) Suspension— \n(1) In general. The Commissioner, or delegate, \nmay suspend the respondent from practice before \nthe Internal Revenue Service by a written notice of \nexpedited suspension immediately following: \n(i) The expiration of the period within which a \nresponse to a show cause order must be filed if the \nrespondent does not file a response as required by \nparagraph (d) of this section; \nTreasury Department Circular No. 230\nTable of Contents\n", " \n \n(ii) The conference described in paragraph (e) \nof this section if the Internal Revenue Service finds \nthat the respondent is described in paragraph (b) of \nthis section; or \n(iii) The respondent’s failure to appear, either \npersonally or through an authorized representative, \nat a conference scheduled by the Internal Revenue \nService under paragraph (e) of this section. \n(2) Duration of suspension. A suspension under \nthis section will commence on the date that the \nwritten notice of expedited suspension is served \non the practitioner, either personally or through \nan authorized representative. The suspension will \nremain effective until the earlier of: \n(i) The date the Internal Revenue Service lifts \nthe suspension after determining that the practitioner \nis no longer described in paragraph (b) of this section \nor for any other reason; or \n(ii) The date the suspension is lifted or \notherwise modified by an Administrative Law Judge \nor the Secretary of the Treasury, or delegate deciding \nappeals, in a proceeding referred to in paragraph (g) \nof this section and instituted under §10.60. \n(g) Practitioner demand for §10.60 proceeding. If \nthe Internal Revenue Service suspends a practitioner \nunder the expedited suspension procedures described \nin this section, the practitioner may demand that \nthe Internal Revenue Service institute a proceeding \nunder §10.60 and issue the complaint described in \n§10.62. The demand must be in writing, specifically \nreference the suspension action under §10.82, and \nbe made within 2 years from the date on which the \npractitioner’s suspension commenced. The Internal \nRevenue Service must issue a complaint demanded \nunder this paragraph (g) within 60 calendar days \nof receiving the demand. If the Internal Revenue \nService does not issue such complaint within 60 days \nof receiving the demand, the suspension is lifted \nautomatically. The preceding sentence does not, \nhowever, preclude the Commissioner, or delegate, \nfrom instituting a regular proceeding under §10.60 \nof this part. \n(h) Effective/applicability date. This section is \ngenerally applicable beginning June 12, 2014, \nexcept that paragraphs (b)(1) through (4) of this \nsection are applicable beginning August 2, 2011. \n \nTreasury Department Circular No. 230\nSubpart E — General Provisions \n§ 10.90 Records. \n(a) Roster. The Internal Revenue Service will \nmaintain and make available for public inspection \nin the time and manner prescribed by the Secretary, \nor delegate, the following rosters — \n(1) Individuals (and employers, firms, or other \nentities, if applicable) censured, suspended, or \ndisbarred from practice before the Internal Revenue \nService or upon whom a monetary penalty was \nimposed. \n(2) Enrolled agents, including individuals — \n(i) Granted active enrollment to practice; \n(ii) Whose enrollment has been placed in \ninactive status for failure to meet the requirements \nfor renewal of enrollment; \n(iii) Whose enrollment has been placed in \ninactive retirement status; and \n(iv) Whose offer of consent to resign from \nenrollment has been accepted by the Internal \nRevenue Service under §10.61. \n(3) Enrolled retirement plan agents, including \nindividuals — \n(i) Granted active enrollment to practice; \n(ii) Whose enrollment has been placed in \ninactive status for failure to meet the requirements \nfor renewal of enrollment; \n(iii) Whose enrollment has been placed in \ninactive retirement status; and \n(iv) Whose offer of consent to resign from \nenrollment has been accepted under §10.61. \n(4) Registered tax return preparers, including \nindividuals — \n(i) Authorized to prepare all or substantially all \nof a tax return or claim for refund; \n(ii) Who have been placed in inactive status for \nfailure to meet the requirements for renewal; \n(iii) Who have been placed in inactive \nretirement status; and \n(iv) Whose offer of consent to resign from \ntheir status as a registered tax return preparer has \nbeen accepted by the Internal Revenue Service \nunder §10.61. \n§ 10.90 — Page 43 \nTable of Contents\n", " \n \n \n \n \n(5) Disqualified appraisers. \n(6) Qualified continuing education providers, \nincluding providers — \n(i) Who have obtained a qualifying continuing \neducation provider number; and \n(ii) Whose qualifying continuing education \nnumber has been revoked for failure to comply with \nthe requirements of this part. \n(b) Other records. Other records of the Director \nof the Office of Professional Responsibility may be \ndisclosed upon specific request, in accordance with \nthe applicable law. \n(c) Effective/applicability date. \n This section is \napplicable beginning August 2, 2011. \n§ 10.91 Saving provision. \nAny proceeding instituted under this part prior to \nJune 12, 2014, for which a final decision has not been \nreached or for which judicial review is still available \nis not affected by these revisions. Any proceeding \nunder this part based on conduct engaged in prior to \nJune 12, 2014, which is instituted after that date, will \napply subpart D and E of this part as revised, but \nthe conduct engaged in prior to the effective date of \nthese revisions will be judged by the regulations in \neffect at the time the conduct occurred. \n§ 10.92 Special orders. \nThe Secretary of the Treasury reserves the power to \nissue such special orders as he or she deems proper \nin any cases within the purview of this part. \n§ 10.93 Effective date. \nExcept as otherwise provided in each section and \nSubject to §10.91, Part 10 is applicable on July 26, \n2002. \nJohn Dalrymple, \nDeputy Commissioner for Services and Enforcement \nApproved: June 3, 2014 \nChristopher J. Meade, \nGeneral Counsel \n[FR Doc. 2014-13739 Filed 06/09/2014 at 4:15 pm; \nPublication Date: 06/12/2014] \nPage 44 — § 10.90 \nTreasury Department Circular No. 230\nTable of Contents\n" ]
f15230b.pdf	1020 Form 15230-B (PDF)	https://www.irs.gov/pub/irs-pdf/f15230b.pdf	[ "Catalog Number 74611Z\nwww.irs.gov\nForm 15230-B (Rev. 10-2020)\nForm 15230-B \n(October 2020)\nDepartment of the Treasury - Internal Revenue Service\nContinuing Service Agreement \n(for Candidate Development Program Participants)\nParticipant name\nTraining\nEstimated cost of training\nAgreement to Continue in Service\nThis agreement applies to candidates selected to participate in the Senior Executive Service Candidate Development Program \n(SESCDP) and includes all training, education, and professional development related to the program for which the federal government \napproves payment of cost prior to commencement. The period of obligated service for participation in the SESCDP will commence the \nday after completing the one to two-year SESCDP. Nothing contained in this section shall be construed as limiting the authority of an \nagency to waive, in whole or in part, an obligation of an employee to pay expenses incurred by the government in connection with this \ntraining.\na. I agree upon completing the SESCDP described in this request, I will serve in the federal service for a period equivalent to at least \nthree times the length of time served in the program. (For example, if a participant remains in SESCDP for a period of one year, four \nmonths, he/she will be required to serve for a period of four years.) Since the SESCDP is a one to two-year program, this agreement \nperiod will be for no less than three calendar years but not-to-exceed six calendar years.\nb. If I voluntarily leave Government service before completing the terms of the agreement, I will be required to repay the cost of training \nand related travel expenses, excluding salary or other compensation. This does not preclude me from pursuing promotion or \nreassignment opportunities within the Federal Government during the program.\nc. If I voluntarily withdraw from the SESCDP and/or leave federal service before completing the period of service agreed to in item (a) \nabove, I agree to reimburse my agency for the tuition and related fees, travel, and other special expenses (excluding salary) paid in \nconnection with my training. However, the amount of the reimbursement will be reduced on a pro-rated basis for the percentage of \ncompletion of the obligated service. (For example, if the cost of training is $3,000 and I complete two-thirds of the obligated service, I \nwill reimburse my agency $1,000.)\nd. I understand any amount which may be due to the employing agency resulting from my failure to meet the terms of this agreement \nmay be withheld from any monies owed me by the government or may be recovered by such other methods as laid out in 5 U.S.C. \n5514.\ne. I acknowledge my agency (according to the Memorandum of Understanding between the host agency and my home agency), must \nterminate this continuing service agreement if I am demoted or separated for cause (i.e. unacceptable performance or conduct); \nreceive a performance rating lower than “Fully Successful”; or otherwise fail to fulfill the terms of this continuing service agreement. \nIn such case, I acknowledge I must repay the full cost of the SESCDP training.\nf. I understand, in extenuating circumstances, I may request a reconsideration of the recovery amount or appeal for a waiver of the \nagency’s right to recover payment. Such extenuating circumstances may include, but are not limited to, personal death, personal \nillness, illness of a close family member, or financial hardship. Procedures for requesting a reconsideration or waiver are established \nunder Internal Revenue Manual 1.35.13.7.\ng. I acknowledge that this agreement does not in any way commit the government to continue my employment.\nh. The period requiring obligated service is the official start date of the Executive Development (XD) training until completion of the one \nto two year program. The completion of the program is indicated by the date the Chair, Executive Resources Board (ERB) signs the \ncertification paperwork for submission to the Office of Personnel Management’s Qualifications Review Board for SES certification.\nFrom\nTo\ni. The period of obligated service is three times the length of your participation in the SESCDP.\nFrom\nTo\nj. I understand signing this continuing service agreement is a requirement for participating in the SESCDP. Failure to sign this \nagreement will result in my declination from participating in the program.\nParticipant signature\nDate\nParticipant’s agency\nSIGN\n" ]
p5412j.pdf	1020 Publ 5412-J (PDF)	https://www.irs.gov/pub/irs-pdf/p5412j.pdf	[ " \nPublication 5412-J (Rev. 10-2020) Catalog Number 74527I Department of the Treasury Internal Revenue Service www.irs.gov \nIndividuals who don’t normally file \ntaxes need to sign up with the IRS \nby November 21. \nPayments are $1,200 per individual \nand $500 per qualifying child. \nEconomic \nImpact \nPayments\n \nfor Americans \nexperiencing homelessness\nThe IRS will mail a letter to your last known address within a few \nweeks after the payment is issued.\nFor more information, visit: www.irs.gov/EIP.\nwww.irs.gov/EIP\nAmericans without a permanent address qualify for a \n$1,200 Economic Impact Payment. \nNo income is required to claim the payment.\nHere’s what’s needed:\n❚ Name, a mailing address and an \nemail address\n❚ Date of birth and valid SSN\n❚ Bank account, if you have one\n❚ IP PIN, if you received one from the \nIRS earlier\n❚ License or state ID, if you have one\n❚ Name, SSN and relationship for each child\nSign up by using the free online tool \nat www.IRS.gov/nonfilereip.\nAct now! \nDeadline to\n register is Nov. 21.\n \n" ]
f3949a.pdf	1020 Form 3949-A (PDF)	https://www.irs.gov/pub/irs-pdf/f3949a.pdf	[ "Catalog Number 47872E\nwww.irs.gov\nForm 3949-A (Rev. 10-2020)\nForm 3949-A \n(October 2020)\nDepartment of the Treasury - Internal Revenue Service\nInformation Referral \n(See instructions on reverse) \nOMB Number \n1545-1960\nUse this form to report suspected tax law violations by a person or a business. \nCAUTION: READ THE INSTRUCTIONS BEFORE COMPLETING THIS FORM. There may be other more appropriate forms specific to your complaint. \n(For example, if you suspect your identity was stolen, use Form 14039.)\nSection A – Information About the Person or Business You Are Reporting\nComplete 1, if you are reporting an Individual. Complete 2, if you are reporting a business only. Complete 1 and 2 if you are reporting a business and its owner. \n(Leave blank any lines you do not know.) \n1a. Name of individual \nb. Social Security Number/TIN\nc. Date of birth\nd. Street address\ne. City\nf. State\ng. ZIP code\nh. Occupation\ni. Email address\nj. Marital status (check one, if known)\nMarried\nSingle\nHead of Household\nDivorced\nSeparated\nk. Name of spouse\n2a. Name of business\nb. Employer Tax ID number (EIN)\nc. Telephone number\nd. Street address\ne. City\nf. State\ng. ZIP code\nh. Email address\ni. Website\nSection B – Describe the Alleged Violation of Income Tax Law\n3. Alleged violation of income tax law. (Check all that apply.)\nFalse Exemption\nFalse Deductions\nMultiple Filings\nOrganized Crime\nUnsubstantiated Income\nEarned Income Credit\nPublic/Political Corruption\nFalse/Altered Documents\nUnreported Income\nNarcotics Income\nKickback\nWagering/Gambling\nFailure to Withhold Tax\nFailure to File Return\nFailure to Pay Tax\nOther (describe in 5) \n4. Unreported income and tax years \nFill in Tax Years and dollar amounts, if known (e.g., TY 2010- $10,000)\nTY\n$\nTY\n$\nTY\n$\nTY\n$\nTY\n$\nTY\n$\n5. Comments (Briefly describe the facts of the alleged violation-Who/What/Where/When/How you learned about and obtained the information in this report. Attach \nanother sheet, if needed.)\n6. Additional information. Answer these questions, if possible. Otherwise, leave blank.\na. Are book/records available? (If available, do not send now. We will contact you, if they are needed for an investigation.)\nYes\nNo\nb. Do you consider the taxpayer dangerous\nYes\nNo\nc. Banks, Financial Institutions used by the taxpayer\nName\nStreet address\nCity\nState\nZIP code\nName\nStreet address\nCity\nState\nZIP code\nSection C – Information About Yourself \n(We never share this information with the person or business you are reporting.) \nThis information is not required to process your report, but would be helpful if we need to contact you for any additional information.\n7a. Your name\nb. Telephone number\nc. Best time to call\nd. Street address\ne. City\nf. State\ng. ZIP code\nPrint and send your completed form to: Internal Revenue Service \nPO Box 3801 \nOgden, UT 84409\n", "Page 2\nCatalog Number 47872E\nwww.irs.gov\nForm 3949-A (Rev. 10-2020)\nInstructions for Form 3949-A, Information Referral\nGeneral Instructions \n \nPurpose of the Form \nUse Form 3949-A to report alleged tax law violations by an individual, a business, or both. \n \n CAUTION: DO NOT USE Form 3949-A:\no If you suspect your identity was stolen. Use Form 14039. Follow “Instructions for Submitting this Form” on Page 2 of \nForm 14039.\no To report suspected misconduct by your tax return preparer. Use Form 14157. Submit to the address on the Form \n14157.\no If your paid preparer filed a return or made changes to your return without your authorization. Instead, use Form 14157 \nAND Form 14157-A. Submit both to the address on the Form 14157-A.\no If you received a notice from the IRS about someone claiming your exemption or dependent. Follow the instructions \non the notice. Do not complete Form 3949-A.\no To report an abusive tax avoidance scheme, promotion, or a promoter of such a scheme. Use Form 14242. Mail or FAX \nto the address or FAX number on the Form 14242.\no To report misconduct or wrongdoing by a tax exempt organization or its officers, directors, or authorized persons. Use \nForm 13909. Submit by mail, FAX, or email, according to the instructions on the Form 13909.\nHave information and want to claim a reward? Use Form 211, Application For Award For Original Information. Mail it to the \naddress in the Instructions for the form. \n \nSpecific Instructions \n \nSection A – Provide Information About the Person/Business You Are Reporting, if known. \nProvide as much information as you know about the person or business you are reporting. \n \n1. Complete if you are reporting an individual. Include their name, street address, city, state, ZIP code, social security \nnumber or taxpayer identification number, occupation, date of birth, marital status, name of spouse (if married), and email \naddress. Include as much information as you know. \n2. Complete if you are reporting a business. Include the business name, business street address, city, state, ZIP code, \nemployer identification number (EIN), telephone number(s), email address, and website, if known. \nNote: Complete both parts if you are reporting a business and its owner. \n \nSection B – Use to Describe the Alleged Tax Law Violation(s) \n \n3. Check all Tax Violations That Apply to Your Report. \nFalse Exemption- Claimed persons as dependents they are not entitled to claim. \nFalse Deductions- Claimed false or exaggerated deductions to reduce their taxable income. \nMultiple Filings- Filed more than one tax return to receive fraudulent refunds. \nOrganized Crime- Member of a group of persons who engaged in illegal enterprises such as drugs, gambling, \nloansharking, extortion, or laundering illegal money through a legitimate business. \nUnsubstantiated Income- Reported false income from an unverifiable source in order to get a false refund. \nEarned Income Credit- Claimed Earned Income Credit which they were not entitled to receive. They may have reported \nincome they did not earn or claimed children they were not entitled to claim. \nPublic/Political Corruption- Public official or politician violated laws against using their position illegally for personal gain. \nFalse/Altered Documents- Changed documents, such as a W-2 or Form 1099, or created fake documents to substantiate a \nfalse refund. \nUnreported Income- Received cash or other untraceable payments, such as goods or services, and did not report the \nincome. \nNarcotics Income- Received income from illegal drugs or narcotics.\n", "Page 3\nCatalog Number 47872E\nwww.irs.gov\nForm 3949-A (Rev. 10-2020)\n \nKickback- Received illegal payments or kickbacks in exchange for referring the business of a government agency or other \nbusiness towards a company or for influencing business decisions that result in part of the payment for the business \nreceived or service performed being returned to the person who made the referral. \nWagering/Gambling- Did not report income received from wagering or gambling. \nFailure to Withhold Tax- Individual or business did not withhold legally owed taxes from income paid to their employee(s), \nsuch as Social Security or Medicare taxes. Example: A business treated employees as independent contractors and \nissued Forms 1099, with no tax withheld, instead of a W-2. \nFailure to File Return- Individual or business has not filed returns legally due. \nFailure to Pay Tax- Individual or business has not paid taxes legally due. \nOther- Describe in 5. \n \n4. If your report involves unreported income, indicate the year(s) and the dollar amount(s). \n5. Briefly describe the facts of the alleged tax law violation(s) as you know them. Attach another sheet, if you need \nmore room. \n6. Additional Information, if known. Attach another sheet, if you need more room. \n \nSection C – Provide Information about Yourself \n \n7. Note: Information about yourself is NOT required to process your report, but may be helpful if we need additional \ninformation. \n \nPrint and send your completed form to the Internal Revenue Service at: \n \nInternal Revenue Service \nPO Box 3801 \nOgden, UT 84409\nPaperwork Reduction Notice \nWe ask for the information on this form to carry out the Internal Revenue laws of the United States. This report is voluntary and the information requested helps us \ndetermine if there has been a violation of Income Tax Law. We need it to insure that taxpayers are complying with these laws and to allow us to figure and collect \nthe right amount of tax. \n \nYou are not required to provide the information on a form that is subject to the Paperwork Reduction Act unless the form displays a valid OMB control number. \nBooks or records relating to a form or its instructions must be retained as long as their contents may become material in the administrations of any Internal \nRevenue laws. Generally, tax returns and tax return information are confidential, as required by Code section 6103. \n \nThe time required to complete this form will vary depending on individual circumstances. The estimated average time is 15 minutes.\nPrivacy Act Notice\nWe are requesting this information under authority of 26 U.S.C. 7801. The primary purpose of this form is to report potential violations of the Internal Revenue \nlaws. The information may be disclosed to the Department of Justice to enforce the tax laws. Providing the information is voluntary. Not providing all or part of the \ninformation will not affect you.\n" ]
p5412jsp.pdf	1020 Publ 5412-J (SP) (PDF)	https://www.irs.gov/pub/irs-pdf/p5412jsp.pdf	[ "Publication 5412-J (SP) (Rev. 10-2020) Catalog Number 74583S Department of the Treasury Internal Revenue Service www.irs.gov \nIndividuos que normalmente no \npresentan impuestos deben inscribirse \ncon el IRS antes del 21 de noviembre.\nPagos son de $1,200 por individuo y \n$500 por niño calificado.\nPagos de \nImpacto \nEconómico\npara estadounidenses \nsin hogar\nEl IRS enviará una carta por correo a su última dirección conocida \ndentro de unas semanas después de que se emita el pago.\nPara más información, visite: www.irs.gov/eip.\nwww.irs.gov/EIP\nEstadounidenses sin una dirección permanente califican \npara el pago de impacto económico de $1,200. \nNo se requieren ingresos para reclamar el pago.\nEsto es lo que se necesita\n \n❚Nombre, dirección postal y una dirección \nde correo electrónico\n \n❚Fecha de nacimiento y un SSN válido\n \n❚Cuenta bancaria, si tiene una\n \n❚IP PIN, si lo recibió del IRS antes\n \n❚Licencia o ID emitida por el estado\n \n❚Nombre, SSN, y relación para cada niño \nInscríbase a través de la herramienta en \nlínea gratuita en IRS.gov/nonfilereip\n¡Actúe ahora! \n Fecha límite de \ninscripción es el 21 de noviembre.\n \n \n" ]
p5423zht.pdf	0620 Publ 5423 (ZH-T) (PDF)	https://www.irs.gov/pub/irs-pdf/p5423zht.pdf	[ "身份竊盜\n打電話、\n傳送電子郵件或傳短訊，\n \n索要納稅人的身份保護識別號碼\n傳送電子郵件給 [email protected] 舉報詐騙。\n \| www.irs.gov/alerts (英文)\n不要上當。\n \n當某人利用您被偷的個人資料提交欺詐性的報稅申請退稅時，\n \n則發生了稅務相關的身份竊盜。\n身份竊盜者利用各種詐騙來欺 \n騙使用者放棄密碼和其他資料。\n國稅局 (IRS) 永遠不會：\n透過電子郵件、\n短訊或社交媒體主動與 \n納稅人聯絡，\n要求提供個人或財務資料\n打電話給納稅人，\n並威脅提起訴訟或逮 \n捕他們\nPublication 5423 (ZH-T) (6-2020) Catalog Number 74837H Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
p5423ht.pdf	0620 Publ 5423 (HT) (PDF)	https://www.irs.gov/pub/irs-pdf/p5423ht.pdf	[ "Vòl Idantite\nRele, voye imèl oswa mesaj tèks \nbay okenn kontribyab pou mande \nyo bay Nimewo Pwoteksyon Idantite \n(Identity Protection PIN) yo\nRapòte tout eskwokri nan [email protected]. \| www.irs.gov/alerts (an Anglè)\nPa pran nan pyèj sa a. \nVòl idantite an rapò ak taks se lè yon moun sèvi ak done pèsonèl lòt moun ke \nli vòlè pou fè yon fo deklarasyon taks epi reklame ranbousman. Vòlè idantite sa yo \nsèvi ak divès eskwokri pou twonpe itilizatè epi fè yo bay modpas yo ak lòt done.\nIRS p ap JANM:\nAntre an kontak ak okenn \nkontribyab atravè imèl, mesaj tèks \nni rezo sosyo pou mande yo bay \ndone pèsonèl oswa finansyè yo\nRele okenn kontribyab pou fè \nmenas jijman oswa arestasyon \nkont yo\nPublication 5423 (HT) (6-2020) Catalog Number 74836W Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
p5423ko.pdf	0620 Publ 5423 (KO) (PDF)	https://www.irs.gov/pub/irs-pdf/p5423ko.pdf	[ "신원 도용\n문자 메시지로 납세자의 신원 보호 \n핀(IP PIN)을 요청하는 행위\n사기 피해는 [email protected] 에 신고하십시오. \| www.irs.gov/alerts (영어)\n미끼에 현혹되지 마십시오.\n세금 관련 신원 도용은 누군가가 귀하의 도난 당한 개인 정보를 사용하여 세금 환급을 \n청구하기 위해 사기성 세금 보고서를 제출할 때 발생합니다. 신원 도용범들은 다양한 \n사기 수법으로 사용자가 패스워드 및 다른 정보를 제공하도록 기만합니다.\nIRS는 아래의 행위를 절대 하지 않습니다.\n개인 또는 금융 정보를 요청하기 위해 전자 \n메일, 문자 메시지 또는 소셜 미디어를 통해 \n납세자와 접촉을 시도하는 행위\n납세자에게 전화를 걸어 소송 또는 체포를 \n하겠다고 위협하는 행위\nPublication 5423 (KO) (6-2020) Catalog Number 74834A Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
p5423ru.pdf	0620 Publ 5423 (RU) (PDF)	https://www.irs.gov/pub/irs-pdf/p5423ru.pdf	[ "Хищение персональных \nданных\nЗапрашивать по телефону, электронной \nпочте или с помощью текстового сообщения \nиндивидуальный номер защиты персональных \nданных налогоплательщика (PIN)\nО случаях мошенничества сообщайте по адресу электронной почты: [email protected].\nwww.irs.gov/alerts (aнглийский)\nНе попадайтесь на такую приманку. \nХищение персональных данных, которые касаются налогов, возникает в том \nслучае, если кто-либо использует похищенную у вас личную информацию для подачи \nфиктивной налоговой декларации с целью получения возмещения за излишне \nуплаченные налоги. Похитители персональных данных используют различные \nуловки, чтобы заполучить от пользователей их пароли и другую информацию.\nНалоговое управление США НИКОГДА не будет:\nОбращаться к налогоплательщикам по \nэлектронной почте, с помощью текстовых \nсообщений или через социальные сети \nс просьбой предоставить личную или \nфинансовую информацию\nЗвонить налогоплательщикам и угрожать \nим судебным преследованием или арестом\nPublication 5423 (RU) (6-2020) Catalog Number 74833P Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
p5423vie.pdf	0620 Publ 5423 (VIE) (PDF)	https://www.irs.gov/pub/irs-pdf/p5423vie.pdf	[ "Mạo danh\nGọi điện, gửi thư điện tử hoặc nhắn \ntin để yêu cầu mã PIN Bảo vệ Danh \ntính của người đóng thuế\nHãy báo cáo các trò lừa đảo cho [email protected]. \| www.irs.gov/alerts (Tiếng Anh)\nĐừng để bị lừa. \nMạo danh liên quan đến thuế xảy ra khi ai đó sử dụng thông tin cá nhân \nbị đánh cắp của quý vị để nộp tờ khai thuế gian lận yêu cầu tiền hoàn thuế. \nNhững kẻ trộm cắp danh tính sử dụng các trò lừa đảo khác nhau để lừa người \ndùng cung cấp mật khẩu và thông tin khác.\nIRS sẽ KHÔNG BAO GIỜ:\nKhởi sự liên lạc với người đóng thuế \nqua thư điện tử, tin nhắn văn bản \nhay phương tiện truyền thông xã \nhội để yêu cầu thông tin cá nhân \nhoặc tài chính\nGọi cho người đóng thuế để đe dọa \nkiện cáo hoặc bắt giữ\nPublication 5423 (VIE) (6-2020) Catalog Number 74835L Department of the Treasury Internal Revenue Service www.irs.gov\n" ]
p5363.pdf	0920 Publ 5363 (PDF)	https://www.irs.gov/pub/irs-pdf/p5363.pdf	[ " \n \nPublication 5363 (Rev. 9-2020) Catalog Number 73307E Department of the Treasury Internal Revenue Service www.irs.gov \n \n \n \nSeptember 2020 \nFederal Tax Law Update Test \nfor Circular 230 Professionals \nfor VITA/TCE Partners and Volunteers \nThis information is intended to provide details on available certifications and requirements for \nvolunteers who are authorized under Circular 230 to practice before the IRS. \nBackground \nIn the 2014 Annual Report to Congress, the National Taxpayer Advocate recommended that the IRS \noffer volunteers who are authorized under Circular 230 to practice before the IRS (i.e. attorneys, \ncertified public accountants and Enrolled Agents) to annually recertify only on new provisions and \nchanges in tax law. As a result of this recommendation the Stakeholder Partnerships, Education & \nCommunication (SPEC) office began offering the Federal Tax Law Update Test for Circular 230 \nprofessionals. \n \nThe test is available on Link & Learn Taxes and is also printed in the Form 6744, VITA/TCE Volunteer \nAssistor’s Test/Retest. This is an optional test for Circular 230 professionals. Volunteers who would \nlike additional training beyond this certification can choose the traditional certification paths (Basic, \nAdvanced, etc.) available to all new and returning volunteers. \nLink & Learn Requirements \n■ \nLink & Learn Taxes Online Certification Learning Management System (LMS) will identify the \nvolunteers who have registered as an attorney, certified public accountant (CPA) or Enrolled Agent \n(EA). These eligible volunteers will have access to this test. \n■ \nAny volunteer who is already registered in the system as an attorney, CPA or EA will not have to \nchange any account settings. However, they must use the same account used in the prior tax year in \norder to access this test. \n■ \nVolunteers who already have a registration in the system and are not identified as an attorney, CPA \nor EA will need to manually change their registration using the My Account feature in Link & Learn \nTaxes to gain access to the test. \n■ \nOnce the eligible volunteer has passed the Volunteer Standards of Conduct (VSC) and \nIntake/Interview & Quality Review certifications, the Federal Tax Law Update Test for Circular 230 \nProfessionals will be available for completion. \n \n \n", "Fact Sheet: Federal Tax Law Update Test for Circular 230 Professionals for VITA/TCE Partners and Volunteers \n2 \n \n \n \nVolunteer Requirements \nThe eligible volunteer must: \n■ \nBe an attorney, CPA or EA with an active license and in good standing. \n■ \nPass, with a score of 80% or higher, both the VSC certification test and Intake/Interview & Quality \nReview certification test. \n■ \nFirst year volunteers must take the Intake/Interview & Quality Review training before taking the \ncertification test. \n■ \nBoth certifications must be passed before taking the Federal Tax Law Update Test for Circular \n230 Professionals. \n■ \nPass the Federal Tax Law Update Test for Circular 230 Professionals with a score of 80% or higher. \n■ \nElectronically sign Form 13615, Volunteer Standards of Conduct Agreement agreeing to the VSC. \n■ \nPrint Form 13615 and record their professional credentials as indicated on their identification card \nwhich includes: professional designation (attorney, CPA or EA), licensing jurisdiction, bar, license, \nregistration or enrollment number, effective or issue date and expiration date (if provided). \n■ \nProvide a copy of the completed Form 13615 and their credentials at the time of volunteering to the \npartner or site coordinator. This should be in the form of a wallet identification card for their \nprofession. \nSPEC Partner Requirements \nThe SPEC partner or site coordinator must: \n■ \nValidate the volunteer’s credentials as indicated on their professional identification card against the \nForm 13615. \n■ \nConfirm the identity of the volunteer using government issued photo identification. \n■ \nVerify the volunteer certified by passing the Federal Tax Law Update Test for Circular 230 \nProfessionals. \n■ \nSign and date the Form 13615 as the authorizing official. \nOnce the required certifications are successfully completed, eligible volunteers are authorized to \nprepare all tax returns within the scope of the VITA/TCE programs. \nNote: SPEC established the minimum certification requirements for volunteers who are authorized \nunder Circular 230; however, partners may establish additional certification requirements for their \nvolunteers. Volunteers should check with the sponsoring SPEC partner. Also, the Federal Tax Law \nUpdate Test for Circular 230 Professionals does not qualify for Continuing Education Credits. Please \nrefer to the Fact Sheet for Continuing Education Credits for the requirements to earn CE Credits in the \nVITA/TCE Program. \n" ]
f9465.pdf	0920 Form 9465 (PDF)	https://www.irs.gov/pub/irs-pdf/f9465.pdf	[ "Form 9465\n(Rev. September 2020)\nInstallment Agreement Request \nDepartment of the Treasury \nInternal Revenue Service \n▶ Go to www.irs.gov/Form9465 for instructions and the latest information. \n▶ If you are filing this form with your tax return, attach it to the front of the return. \n▶ See separate instructions. \nOMB No. 1545-0074\nTip: If you owe $50,000 or less, you may be able to avoid filing Form 9465 and establish an installment agreement online, even if you \nhaven’t yet received a tax bill. Go to www.irs.gov/OPA to apply for an Online Payment Agreement. If you establish your installment \nagreement using the Online Payment Agreement application, the user fee that you pay will be lower than it would be with Form 9465.\nPart I\nInstallment Agreement Request\nThis request is for Form(s) (for example, Form 1040 or Form 941) ▶\nEnter tax year(s) or period(s) involved (for example, 2018 and 2019, or January 1, 2019, to June 30, 2019) ▶\n1 \na \nYour first name and initial \nLast name \nYour social security number \nIf a joint return, spouse’s first name and initial Last name \nSpouse’s social security number\nCurrent address (number and street). If you have a P.O. box and no home delivery, enter your box number. \nApt. number \nCity, town or post office, state, and ZIP code. If a foreign address, also complete the spaces below (see instructions).\nForeign country name \nForeign province/state/county Foreign postal code \n1 \nb If this address is new since you filed your last tax return, check here \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n▶\n2 \nName of your business (must no longer be operating)\nEmployer identification number (EIN)\n3\nYour home phone number \nBest time for us to call \n4 \nYour work phone number \nExt. \nBest time for us to call \n5 \nEnter the total amount you owe as shown on your tax return(s) (or notice(s)) .\n.\n.\n.\n.\n.\n.\n.\n5\n6 \nIf you have any additional balances due that aren’t reported on line 5, enter the amount here (even if\nthe amounts are included in an existing installment agreement)\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n6\n7 \nAdd lines 5 and 6 and enter the result \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n7 \n8 \nEnter the amount of any payment you’re making with this request. See instructions \n.\n.\n.\n.\n.\n8 \n9 \nAmount owed. Subtract line 8 from line 7 and enter the result \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n9\n10\nDivide the amount on line 9 by 72.0 and enter the result \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n10\n11 \n \n \n \na \n \n \n \nEnter the amount you can pay each month. Make your payment as large as possible to limit interest \nand penalty charges, as these charges will continue to accrue until you pay in full. If you have\nan existing installment agreement, this amount should represent your total proposed monthly\npayment amount for all your liabilities. If no payment amount is listed on line 11a, a payment will\nbe determined for you by dividing the balance due on line 9 by 72 months .\n.\n.\n.\n.\n.\n.\n11a $\nb If the amount on line 11a is less than the amount on line 10 and you’re able to increase your payment \nto an amount that is equal to or greater than the amount on line 10, enter your revised monthly payment\n11b $\n• If you can’t increase your payment on line 11b to more than or equal to the amount shown on line 10, check the box. Also, \ncomplete and attach Form 433-F, Collection Information Statement .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n• If the amount on line 11a (or 11b, if applicable) is more than or equal to the amount on line 10 and the amount you owe is \nover $25,000 but not more than $50,000, then you don’t have to complete Form 433-F. However, if you don’t complete Form \n433-F, then you must complete either line 13 or 14.\n• If the amount on line 9 is greater than $50,000, complete and attach Form 433-F.\n12\nEnter the date you want to make your payment each month. Don’t enter a date later than the 28th \n12\n13 \nIf you want to make your payments by direct debit from your checking account, see the instructions and fill in lines 13a and \n13b. This is the most convenient way to make your payments and it will ensure that they are made on time. \n▶a Routing number \n▶b Account number \nI authorize the U.S. Treasury and its designated Financial Agent to initiate a monthly ACH debit (electronic withdrawal) entry to the financial institution account \nindicated for payments of my federal taxes owed, and the financial institution to debit the entry to this account. This authorization is to remain in full force and \neffect until I notify the U.S. Treasury Financial Agent to terminate the authorization. To revoke payment, I must contact the U.S. Treasury Financial Agent at \n1-800-829-1040 no later than 14 business days prior to the payment (settlement) date. I also authorize the financial institutions involved in the processing of the \nelectronic payments of taxes to receive confidential information necessary to answer inquiries and resolve issues related to the payments. \nc \n \nLow-income taxpayers only. If you’re unable to make electronic payments through a debit instrument by providing your \nbanking information on lines 13a and 13b, check this box and your user fee will be reimbursed upon completion of your \ninstallment agreement. See instructions .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n14\nIf you want to make payments by payroll deduction, check this box and attach a completed Form 2159 .\n.\n.\n.\n.\n.\n.\nBy signing and submitting this form, I authorize the IRS to contact third parties and to disclose my tax information to third parties in order to process this \nrequest and administer the agreement over its duration. I also agree to the terms of this agreement, as provided in the instructions, if it’s approved by the IRS.\nYour signature \nDate \nSpouse’s signature. If a joint return, both must sign. \nDate \nFor Privacy Act and Paperwork Reduction Act Notice, see instructions. \nCat. No. 14842Y \nForm 9465 (Rev. 9-2020)\n", "Form 9465 (Rev. 9-2020) \nPage 2 \nPart II\nAdditional Information\nComplete this Part only if all three conditions below apply: \n1. You defaulted on an installment agreement in the past 12 months;\n2. You owe more than $25,000 but not more than $50,000; and\n3. The amount on line 11a (or 11b, if applicable) is less than line 10.\nNote: If you owe more than $50,000, also complete and attach Form 433-F.\n15\nIn which county is your primary residence?\n16a Marital status:\nSingle. Skip question 16b and go to question 17. \nMarried. Go to question 16b.\nb Do you share household expenses with your spouse?\nYes.\nNo.\n17\nHow many dependents will you be able to claim on this year’s tax return?.\n.\n.\n.\n.\n.\n.\n.\n.\n17\n18\nHow many people in your household are 65 or older? \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n18\n19\nHow often are you paid?\nOnce a week.\nOnce every 2 weeks.\nOnce a month.\nTwice a month.\n20\nWhat is your net income per pay period (take home pay)? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n20 $\nNote: Complete lines 21 and 22 only if you have a spouse and meet certain conditions (see instructions). If you don’t \nhave a spouse, go to line 23.\n21\nHow often is your spouse paid?\nOnce a week.\nOnce every 2 weeks.\nOnce a month.\nTwice a month.\n22\nWhat is your spouse’s net income per pay period (take home pay)? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n22 $\n23\nHow many vehicles do you own? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n23\n24\nHow many car payments do you have each month? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n24\n25a Do you have health insurance?\nYes. Go to question 25b.\nNo. Skip question 25b and go to question 26a.\nb Are your health insurance premiums deducted from your paycheck?\nYes. Skip question 25c and go to question 26a.\nNo. Go to question 25c.\nc\nHow much are your monthly health insurance premiums? .\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n25c $\n26a Do you make court-ordered payments?\nYes. Go to question 26b.\nNo. Go to question 27.\nb Are your court-ordered payments deducted from your paycheck?\nYes. Go to question 27.\nNo. Go to question 26c.\nc\nHow much are your court-ordered payments each month? \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n26c $\n27 \nNot including any court-ordered payments for child and dependent support, how much do you pay\nfor child or dependent care each month? \n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n.\n27 $\nForm 9465 (Rev. 9-2020) \n" ]

Subsets and Splits

No community queries yet

The top public SQL queries from the community will appear here once available.