IRS is significantly increasing the number of Forms 1120F they will be examining in 2012

Over the last year, the IRS Large Business and International organization (LB&I) has been making a significant shift in the type of tax returns they are placing under audit. This has been seen in the number of flow-through returns such as Form 1065 partnership returns and Form 1120S corporate returns the IRS has been putting into the audit pipeline. There now appears to be a coordinated effort by LB&I to examine many more Forms 1120-F, "U.S. Income Tax Return of a Foreign Corporation."