The IRS Large Business and International Division (LB&I) has announced its first 13 issue campaigns, which will serve as focus areas for examination and compliance efforts. Through the use of issue campaigns, LB&I's goal is to improve return selection, identify issues representing a risk of non-compliance, and make the greatest use of limited resources. The first 13 campaigns consist of the following:

— IRC 48C Energy Credit Campaign
— Offshore Voluntary Disclosure Program Declines-Withdrawals Campaign
— Domestic Production Activities Deduction, Multi-Channel Video Program Distributors and TV Broadcasters Campaign
— Micro-Captive Insurance Campaign
— Related Party Transactions Campaign
— Deferred Variable Annuity Reserves & Life Insurance Reserves IIR Campaign
— Basket Transactions Campaign
— Land Developers - Completed Contract Method Campaign
— TEFRA Linkage Plan Strategy Campaign
— S Corporation Losses Claimed in Excess of Basis Campaign
— Repatriation Campaign
— Form 1120-F Non-Filer Campaign
— Inbound Distributor Campaign

This announcement signals LB&I's move toward issue-based examinations and a compliance campaign process that uses multiple treatment streams, including development of technical guidance in the form of practice units for examiners, issuance of "soft" letters and issue-based examinations.

A detailed Tax Alert is being prepared.