Overview
IRS Announces Selection of Five Large Business and International Compliance Campaigns: Today, the IRS Large Business and International Division announced the roll-out of five additional compliance campaigns:
- Restoration of Sequestered AMT Credit Carryforward (a campaign for taxpayers improperly restoring the sequestered Alternative Minimum Tax credit to a subsequent tax year)
- S Corporation Distributions (the failure to report gain upon the distribution of appreciated property to a shareholder, the failure to determine that a distribution is properly taxable as a dividend, and the failure of a shareholder to report non-dividend distributions in excess of stock basis that are subject to taxation)
- Virtual Currency (noncompliance related to the use of virtual currency)
- Repatriation via Foreign Triangular Reorganizations (Notice 2016-73 curtailed the claimed "tax-free" repatriation of basis and untaxed CFC earnings following the use of certain foreign triangular reorganization transactions)
- The Section 965 Transition Tax