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The IRS Faces Challenges to Address Tax Avoidance Strategies of Large Multinational Corporations

The Commissioner, LB&I Division, should review the Division’s examination procedures to determine whether changes are needed in support of effective tax administration for large complex taxpayers e.g., large multinational corporations. This should include, but not be limited to, the use of the Economic Substance Doctrine, Principles of Collaboration, and the CAP program.