Gary Wells, Of Counsel, published this great article in Tax Notes Today.
IRS has identified thirteen key areas it considers “high risk”.
The 13 campaigns or areas the division plans to target include:
1. examinations of the energy credit described in Internal Revenue Code 48C;
2. declines and withdrawals from the offshore voluntary disclosure program;
3. related-party transactions;
4. repatriation of income from overseas locations;
5. foreign companies doing business in the United States that are not filing appropriately;
6. transfer pricing associated with inbound distribution of goods from related parties outside the United States;
7. deferred variable annuity reserves and life insurance reserves;
8. basket transactions that seek to treat ordinary income and short-term capital gain as long-term;
9. micro-captive insurance contracts;
10. the completed contract method of accounting applied by land developers;
11. application of the domestic production activities deduction to certain entertainment products;
12. risks associated with larger, more complex pass-through partnerships; and
13. losses claimed in excess of basis in S corporations.