LB&I Directives provide administrative guidance to LB&I examiners to ensure consistent tax administration and on matters relating to internal operations. The Directives do not establish Service position on legal issues and are not legal guidance. LB&I (formerly LMSB) Directives 2020 03-10-20 LB&I Directive on the Centralized Risking of Research Issues under IRC §§ 41 & 174 2019 10-10-19 LB&I and SB/SE Joint Directive on the Work Opportunity Tax Credit per Internal Revenue Code Section 51 (IRC § 51) 08-06-19 LB&I and SBSE Joint Directive on Creditability of French Social Taxes 07-31-19 Withdrawal of Directive LB&I-04-0118-005, Instructions for Examiners on Transfer Pricing Issue Selection – Cost-Sharing Arrangement Stock Based Compensation, dated January 12, 2018 05-21-19 Withdrawal of Directive LB&I-04-0118-004, Instructions for Examiners on Transfer Pricing Issue Selection-Reasonably Anticipated Benefits in Cost Sharing Arrangements 2018 11-29-18 LB&I Directive on Amended Return/Claim for Refund Relating to Internal Revenue Code Section 199 (IRC § 199) 08-27-18 LB&I Directive on Timeshare Issue 08-24-18 IRC Section 807: LB&I Directive Related to Principle Based Reserves for Variable Annuity Contracts (AG 43/VM-21) and Life Insurance Contracts VM-20) 01-12-18 Interim Instructions on Issuance of Mandatory Transfer Pricing Information Document Request (IDR) in LB&I Examinations 01-12-18 Instructions for Examiners on Transfer Pricing Issue Examination Scope - Appropriate Application of IRC §6662(e) Penalties 01-12-18 Instructions for LB&I on Transfer Pricing Issue Selection- Reasonably Anticipated Benefits in Cost Sharing Arrangements 01-12-18 Instructions for LB&I on Transfer Pricing Selection and Scope of Analysis - Best Method Selection 2017 10-19-17 Large Business & International Directive for Determining Units of Property and Major Components in the Mining Industry 09-11-17 Activities under I.R.C §41 for Taxpayers that Expense Research and Development Costs on their Financial Statements pursuant to ASC 730 09-11-17 Large Business & International Directive for Determining Units of Property and Major Components in the Mining Industry 2015 07-06-15 LB&I Directive for Determining When "Substantially All" of a Major Component (as Defined in Revenue Procedure 2013-24) has been Replaced under I.R.C. Section 263(a) 04-16-15 LB&I Directive on the Examination of Taxpayers Using the Safe Harbor Methods of Accounting for Cable Network Assets 03-16-15 LB&I Directive on the I.R.C. § 199 Definition of "Manufactured, Produced, Grown, or Extracted" 2014 10-24-14 LB&I Directive Related to § 166 Deductions for Eligible Debt and Eligible Debt Securities 10-14-14 Allocating Mixed Service Costs Under I.R.C. Section 263A to Certain Self-Constructed Property of Electric and Natural Gas Utilities 09-03-14 Large Business & International Directive Extending Transition Rules and the Scope Limitation Waiver for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property-LB&I Directive #3 07-17-14 I.R.C. §446: LB&I Directive for Hedging of Variable Annuity Guaranteed Minimum Benefits (GMxB) by Insurance Companies 03-18-14 LB&I Directive for the Use of MFT C6 on FBAR Examination Cases 01-27-14 Updated Guidance on the Examination of Milestone Payments in the Acquisition of Businesses 01-21-14 De-coordination of All LB&I Coordinated Issue Papers 2013 10-29-13 Updated Guidance for Examiners on I.R.C. § 199 Benefits and Burdens of Ownership Analysis in Contract Manufacturing Arrangements 07-24-13 Guidance for Examiners on I.R.C. § 199 Benefits and Burdens of Ownership Analysis in Contract Manufacturing Arrangements 06-10-13 Large Business & International Directive for Taxpayers Changing to the Method of Accounting Provided in Rev. Proc. 2013-24 for Steam or Electric Generation Property 05-02-13 Extension of Transition Rules for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property - LB&I Directive #2 03-22-13 UPDATED LB&I DIRECTIVE for Taxpayers Who Adopted a Method of Accounting Relating to the Conversion of Capitalized Assets to Repair Expense under I.R.C. Section 263(a) 2012 12-07-12 Guidance for Computing and Substantiating the Credit for Increasing Research Activities under Section 41 of the Internal Revenue Code for Activities involved in Developing New Pharmaceutical Drugs and Therapeutic Biologics 07-30-12 I.R.C. §166: LB&I Directive Related to Partial Worthlessness Deduction for Eligible Securities Reported by Insurance Companies 01-23-12 Large Business and International Directive Wireless Telecommunication Assets 01-23-12 Large Business & International Directive Telecommunication Carriers Change in Method of Accounting Relating to Conversion of Capitalized Assets to Repair Expense Under I.R.C. Section 263(a) 2011 11-25-11 Large Business & International Directive Transition Rules for Taxpayers Adopting the Safe Harbor Method of Accounting for Electric Transmission and Distribution Property 11-01-11 UTP Guidance and Procedures for the Field 07-28-11 Examination of Success-Based Fees in the Acquisition of Businesses 04-14-11 I.R.C. §475: Field Directive related to Mark-to-Market Valuation Frequently Asked Questions for I.R.C. § 475 03-30-11 Industry Director's Directive # 2—Employment Tax and the Employees on the U.S. Outer Continental Shelf 03-28-11 LB&I Alert - Cases Forwarded to Appeals That Involve a Section 965 Transfer Pricing Adjustment Under Section 482 02-04-11 Industry Directive to Withdraw Prior IDD on FSC IRC § 921-927 Bundle of Rights in Software Issue 2010 05-20-10 Examination of Dividends Received Deduction on Separate Accounts of Life Insurance Companies 05-13-10 Use of Delegation Order (DO) 4-25 on Appeals Settlement Position (ASP) for the I.R.C. § 41 Research Credit – Intra-Group Receipts from Foreign Affiliates (IRM 4.46.5.6) 2009 11-03-09 Field Directive on the Use of Estimates from Probability Samples PDF 2006 07-31-06 Industry Director Directive on Deductibility of Casino Complimentary Goods and Services 03-16-06 Industry Director Directive on Treatment of Semiconductor Assembly and Test Activities as Manufacturing 01-13-06 Industry Director Directive on Examination of IRC § 847 2005 11-28-05 Industry Director Directive on the Planning and Examination of Cost Segregation Issues in the Biotech/Pharmaceutical Industry 08-26-05 Industry Director Directive Amended Returns/Refund Claims Containing Invalid IRC § 280(C)(3) Elections 05-20-05 Industry Director Directive Examination of Transaction Costs in the Acquisition of Businesses 03-04-05 Field Guidance on the Planning and Examination of the Cyclical Overhauls, Betterments, and Rebuilds of Locomotives for Class I Railroads 03-04-05 Field Guidance on the Planning and Examination of the Cyclical Overhauls, Betterments, and Rebuilds of Freight Cars for Class I Railroads 01-05-05 Industry Director Directive on Disposition of Income Forecast Method Issues 2004 12-27-04 Planning and Examination of Cost Segregation Issues in the Restaurant Industry 12-16-04 Planning and Examination of Cost Segregation Issues in the Retail Industry 10-12-04 IRC Sec. 907 Evaluating Taxpayer Methods of Determining Foreign Oil and Gas Extraction Income (FOGEI) and Foreign Oil Related Income (FORI) 07-31-04 Cost Depletion - Determination of Recoverable Reserves 04-30-04 Planning and Examination of Research Credit Issues in a Branded Pharmaceutical Company ° Pharmaceutical Industry Research Credit Audit Guidelines ° Exhibit B - Hypothetical Organizational Chart PDF ° Exhibit C - Departmental Reporting Structure (Research Career Ladder) PDF ° Exhibit D - Research Credit Wage Issue Chart 04-16-04 Timber Casualty Losses ° Exhibit A - Timber Casualty Loss Audit Techniques Guide PDF ° Exhibit B - Issue Paper on Timber Casualty Losses - Valuation of a Single Identifiable Property 2003 11-14-03 Foreign Sales Corporations (FSC) IRC § 921-927 Bundle of Rights in Software Issue 10-24-03 Examination Procedures for Sports Franchise Acquisitions 10-24-03 Examination of Sports Franchise Acquisitions 10-17-03 Examination of Legally Mandated Research and Experimentation Expenses in the Biotech and Pharmaceutical Industries 03-24-03 Planning and Examination of Construction "Tenant" Allowances for Leases Greater Than 15 Years 2002 04-26-02 Guidelines for Intangibles Under IRC § 263(a) 04-08-02 MACRS Asset Categories for Refinery Assets 02-25-02 Audit Procedures for Golf Course Land Improvements - Change in Accounting Method 02-07-02 Depreciable Golf Course Land Improvements and the Impact of Rev. Rul. 2001-60 2020 12-12-01 Conformity Election for Bank Bad Debts
