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Top 24 IRS “Campaign” Items

February 22, 2018

The previous blog mentioned 24 targeted “campaigns” the IRS is conducting in lieu of audits. The campaign consists of inquiring letters questioning specific transactions. I received a few calls asking what these “hit list” items are so here is the list. This was also provided by Peter Weitsen.

  • Section 48C energy credits
  • Declines and withdrawals of the Offshore Voluntary Disclosure Program
  • Section 199 domestic production activities deduction (DPAD) deductions by multi-channel video program distributors and TV broadcasters
  • Micro-captive insurance arrangements
  • Related-party transactions between commonly controlled entities
  • Deferred variable annuity reserves and life insurance reserves
  • Basket transactions
  • Land developers and the completed contract method
  • Tax Equity and Fiscal Responsibility Act linkage
  • S corporation losses claimed in excess of basis
  • Repatriation of foreign earnings for middle-market taxpayers
  • Form 1120-F non-filers
  • Form 1120-F Chapter 3 and Chapter 4 withholding
  • Inbound distributors
  • Swiss bank program
  • Foreign earned income exclusion
  • Verification of Form 1042-S credit claimed on Form 1040NR
  • Agricultural chemicals security credit
  • Deferral of cancellation of indebtedness income
  • Energy efficient commercial building property
  • Corporate direct (section 901) foreign tax credit (FTC)
  • Section 956 avoidance
  • Economic development incentives
  • Individual foreign tax credit (Form 1116)

While the original targets are large and international entities, some of these also apply to individuals and smaller closely held businesses. If you have any questions you can contact Peter at

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