IRS Tax: Official previews 'possible' international projects for IRS business plan

An Internal Revenue Service official on October 21 offered a skeletal list of "possible" international projects for the 2009-2010 Treasury-IRS priority guidance plan. Speaking at a panel discussion hosted by the Taxation Section of the DC Bar, IRS Deputy Associate Chief Counsel (International) Mike DiFronzo said he expects the new plan to be released "in a matter of weeks."

New projects may address offshore compliance, tax evasion, and withholding – an issue DiFronzo identified as "the big one." Energy-related projects – for example, emissions and carbon credits and the use of electricity under subpart F – also may appear. Other possibilities include projects related to foreign tax credits, mergers and acquisitions, and deferral, he said.

Taxpayers also should expect some leftover projects from the 2008-2009 business plan related to passive foreign investment companies, reduction in taxpayer burden, compliance (information gathering), overall domestic losses, and the "two baskets" for the foreign tax credit limitation, DiFronzo said.