The IRS's Large Business and International Division (LB&I) has issued a directive ( LB&I-04-0114-002) de-coordinating all its coordinated issue papers (CIPs).
The directive sets forth procedures under Section 4.51.2.4 of the Internal Revenue Manual for de-coordination of CIPs and is the result of various changes to the way LB&I addresses industry-specific examination techniques and knowledge management. To the extent that any CIP included guidance or tools relevant to addressing an issue or transaction, those resources will be made available to examiners through LB&I's issue practice groups (IPGs) and international practice networks (IPNs).
IPGs and IPNs were designed by the IRS to build internal knowledge management systems capable of delivering decentralized, consistent technical advice to examination teams as a way to replace the former tiered issue process used by LB&I. The IPGs and IPNs were meant to be resources for examiners confronting issues with which they were unfamiliar, whether those issues were domestic or international in scope.
In the directive, the IRS said some issues or procedures currently addressed in a CIP may be addressed in future LB&I directives or other guidance, and that the de-coordination of any previously coordinated issue will have no effect on whether the issue will continue to be pursued by the IRS in exam. Nor will de-coordination influence the IRS's views regarding any transaction, including listed transactions.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
