On August 4, the IRS announced that it is reorganizing and changing the name of its Large and Mid-Size Business (LMSB) division as part of its ongoing effort to focus more on international tax compliance (IR-2010-88). Starting October 1, the division will be known as the Large Business and International (LB&I) division.
The reorganization is designed to create a centralized group to handle the IRS’ international tax compliance efforts. As part of the reorganization, the IRS international program will grow from nearly 600 employees to almost 1,500. The new staff will comprise additional examiners, economists and technical staff, most of whom currently focus on international issues in other parts of the LMSB division. The international program will include a transfer pricing director and a chief economist.
The reorganization is the latest evidence of the IRS’ recent focus on international tax compliance, which included last year’s voluntary compliance program for taxpayers with undisclosed foreign accounts and substantial changes to Form 926, Return by a U.S. Transferor of Property to a Foreign Corporation. As part of the announcement, IRS Commissioner Doug Shulman said, “Executing our international strategy is a top priority, and our work continues to intensify in this area.”
The LB&I division will also handle implementation of changes mandated by the recently enacted Foreign Account Tax Compliance Act (FATCA), which was part of the Hiring Incentives to Restore Employment (HIRE) Act, P.L. 111-147.
In addition to the beefed-up international program, the LB&I division will continue to handle the corporations, S corporations, and partnerships with assets greater than $10 million currently handled by the LMSB division.