The Internal Revenue Service’s tax-exempt bond office will update its annual Internal Revenue Manual late this fall with a section on written post-issuance compliance procedures, an agency official said.
Speaking on a panel here at the Council of Development Finance Agencies’ National Development Finance Summit, Chris Woodin, lead tax law specialist at TEB, said that the IRM update will be primarily for revenue agents.
“It will inform the agent what to look for when evaluating those written procedures,” Woodin told The Bond Buyer. “The idea is that it will at least give issuers some idea of what the IRS is looking for. It won’t be a safe harbor or guidance. The IRM is not guidance but it’s something, it’s better than nothing.”
Woodin said TEB has discussed with the chief counsel’s office whether this IRM update could be turned into a revenue procedure. However, those discussions haven’t amounted to anything concrete, but it still could be possible in the future, he said.
IRMs are intended to be published annually, but a new one hasn’t been published in several years.
TEB has had an ongoing effort over the past several years to promote post-issuance compliance for issuers. Most recently in June the Service published an educational paper summarizing processes to help issuers comply with federal tax law requirements.
The IRS has said that consistent due diligence with post-issuance compliance will help an issuer prevent violations from occurring.
Separately, Woodin said that TEB is on track to complete approximately 1,000 exams this year, both compliance check and full blown audits.