Carlene Lowry

The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures.1 Specifically, the IGM (1) removes the Acknowledgement of Facts Information Document Request from the audit process, (2) clarifies the applicability of Accelerated Issue Resolution to Large Corporate Compliance cases, and (3) revises and implements procedural rules to enhance participation in the Fast Track...

Earlier this year, the IRS launched a Voluntary Disclosure Program (VDP) under which taxpayers could return Employee Retention Credits (ERCs) received based on inaccurate or ineligible filings. The initial phase of the VDP was time-limited, with applications open through March 22, 2024. Despite this short duration, the VDP saw significant utilization resulting in large recoveries for the IRS and audit avoidance for certain taxpayers.

Earlier this year, the IRS launched a Voluntary Disclosure Program (VDP) under which taxpayers could return Employee Retention Credits (ERCs) received based on inaccurate or ineligible filings. The initial phase of the VDP was time-limited, with applications open through March 22, 2024. Despite this short duration, the VDP saw significant utilization resulting in large recoveries for the IRS and audit avoidance for certain taxpayers.