The IRS launched a compliance campaign targeting issues arising
out of the 2017 Tax Cuts and Jobs Act ("TCJA") on May 1,
2020.1 The Large Business & International Division
("LB&I") has released a number of issue-based
compliance campaigns in recent years, including one targeting the
so-called repatriation tax enacted under the TCJA in Internal
Revenue Code Section 965. For previous coverage of the Section 965
compliance campaign, please click here.
LB&I's announcement of the TCJA campaign explains that
it will "closely monitor issues on a select pool of returns
and share information learned throughout LB&I and the
IRS."2 The campaign's goals are to identify
transactions and restructurings to better understand taxpayers'
behavior under the TCJA. LB&I explained that the treatment
streams may include examinations, soft letters, outreach, new
practice units, and the development of future campaigns. As part of
the TCJA campaign, the IRS will also consider the impact of
