Tax insight

IRS seeks to streamline exams for large corporate taxpayers

Insight
5 minute read
August 04, 2025

What happened?

On July 23, 2025, the IRS Large Business and International (LB&I) Division issued a memorandum detailing changes to examinations of large corporate taxpayers. The memorandum modifies policies and practices in the Internal Revenue Manual (IRM) by eliminating the sometimes time-consuming process to obtain mutual agreement of facts of a dispute, revising procedures for expedited dispute resolution during audits, and clarifying how agreements on recurring issues apply across multiple tax years.

Why is it relevant?

The changes made by the memorandum, some of which were effective on August 1, 2025, will have an immediate impact on current and future IRS examinations of corporations. The updates generally streamline the audit process, clarify dispute resolution options, and establish clearer procedures for handling recurring issues, which may affect how companies and the IRS interact, resolve disputes, and address issues across multiple tax years.

Action to consider 

Companies undergoing or anticipating IRS examinations should review these new procedures and consider how they may impact their audit strategies and communications with IRS teams.

Maintaining open communication with IRS exam teams and understanding the updated options for resolving disputes will be important under the revised framework.