Wanted by the IRS: Issues for the Industry Issue Resolution Program
The IRS has announced that it is encouraging business taxpayers, among others, to submit tax issues involving a controversy or dispute to its Industry Issue Resolution, or IIR, program. If you’re interested, you’ll want to hurry; issues must be submitted by August 31, 2011 to be included in the next review.
To be sure, this isn’t just an opportunity to rant about taxes; instead, the objective of the program is for the IRS to help resolve tax issues that impact significant numbers of taxpayers by developing improved guidance.
The issues most appropriate for the program involve at least two of the following characteristics, the IRS says:
- Uncertainty about the proper tax treatment of a common factual situation
- The uncertainty results in frequent, often repetitive, examinations of the same issue
- The uncertainty burdens taxpayers
- The issue is significant and impacts a large number of taxpayers
- The issue requires extensive factual development
Issues not suitable for the program are those that involve a limited number of taxpayers, involve transactions that are primarily to improperly reduce or avoid paying federal taxes, or involve units of the IRS other than then Large and Mid-Size Business or the Small Business/Self-Employed divisions.
Among the issues recently selected for review are these: repair versus capitalization in the cable industry and tax accounting issues important to life insurers that issue variable annuities. Among those rejected: TIN masking on Forms 1099 and 5498, and the taxability on the sale of state income tax credits.
When an issue is selected, an team of IRS and Treasury personnel gather information from taxpayers and other interested parties, with the goal of developing and recommending guidance to resolve the problem.
Requests for the IRS to review an issue can be made at any time at IIR@irs.gov or by mail; submission procedures are outlined here. All submissions are available for public viewing.
The requests are reviewed twice a year; the next review takes place on September 1, 2011. Again, submissions must be received by August 31, 2011 to be considered in this round.








