LB&I Imposes Tighter Timeline For Information Document Requests

The IRS Large Business and International Division (LB&I) has announced new, mandatory issuance and enforcement procedures for information document requests (IDRs). The new procedures will greatly diminish examiners' discretion when taxpayers provide a late or incomplete response.

The new directive requires examiners to discuss potential IDRs with the taxpayer to explain their purpose and scope before the IDRs are issued. If examiners determine an IDR is necessary, they must ensure that each IDR clearly states the issue being considered; requests only information related to that issue; is clearly and concisely written; is customized to the taxpayer's industry; and is narrowly tailored to a single, relevant issue, among other things.