IR-2021-88, April 19, 2021
WASHINGTON As part of the continued focus on compliance issues, the Internal Revenue Service announced today the establishment of the IRS Office of Promoter Investigations. The new office will further expand on the efforts of the Promoter Investigations Coordinator that began last summer. By establishing the Office of Promoter Investigations, we are continuing our increased focus on promoters of abusive tax avoidance transactions, which we have demonstrated over the last year, said IRS Commissioner Chuck Rettig. This office will coordinate efforts across multiple business divisions to address abusive syndicated conservation easements and abusive micro-captive insurance arrangements, as well as other transactions.
MAP is an integral component of the international tax system
On November 18, the OECD released a public consultation document concerning BEPS Action 14, which aims to make treaty-based dispute resolution mechanisms more effective. The consultation document contains a number of proposals that, if adopted, would improve dispute resolution and eliminate some longstanding issues.
In 2015, the Inclusive Framework on BEPS committed to adhere to an Action 14 minimum standard. The minimum standard is meant to ensure that taxpayers can access the mutual agreement procedure (MAP) under treaties, and that MAP cases are resolved in a timely and effective manner. The Inclusive Framework also endorsed several optional best practices related to MAP.