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ARTICLE · 15 AUGUST 2025

Faster Audits, More ADR: IRS Rolls Out Significant LB&I Changes

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On July 23, 2025, the Internal Revenue Service ("IRS") issued interim guidance for Large Business & International Division ("LB&I") audit procedure. The IRS announced three major changes: (1) the Acknowledgement...

United StatesAccounting and Audit
S. Starling Marshall
S. Starling Marshall
Carina Federico
Carina Federico
Eleanor Moran McWaters
Eleanor Moran McWaters
Christopher Gurley
Christopher Gurley
Nicholas L. Roberti
Nicholas L. Roberti

On July 23, 2025, the Internal Revenue Service ("IRS") issued interim guidance for Large Business & International Division ("LB&I") audit procedure. The IRS announced three major changes: (1) the Acknowledgement of Facts Information Document Request ("AOF IDR") will be eliminated; (2) Accelerated Issue Resolution ("AIR") applies to Large Corporate Compliance ("LCC") cases; and (3) the IRS must conduct additional review before denying a taxpayer's request to participate in the Fast Track Settlement ("FTS"). These changes reflect the IRS's continued push to make its examinations "more efficient and current."

The End of AOF IDRs

The most meaningful change announced by the IRS is that the AOF IDR is optional through the end of 2025, followed by a complete phase-out in 2026.

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