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An overview by Covington, Taxand USA
The IRS Large Business and International Division has recently issued interim guidance aimed at improving efficiency in large corporate audits.
Key changes include eliminating the “Acknowledgement of Facts” process from 2026, confirming the availability of the Accelerated Issue Resolution process in Large Corporate Compliance cases, and tightening procedures for denying Fast Track Settlement requests. The reforms aim to reduce cycle times, encourage earlier dialogue, and provide greater certainty for recurring issues, offering large taxpayers opportunities to resolve audits more quickly.
Kevin Otero, Sean M. Akins and Joseph Sullivan from Covington, Taxand USA have published an overview of the new guidance and implications for business, which can be read here.
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