Among the nine items listed by the IRS as key Employee Plans Division (EP) priorities for Fiscal Year 2010, two target the employee benefit plans of multinational companies and plans with international investments. The very first item on the list indicates the Service will “develop strategies and capabilities to address key international issues impacting the Employee Plans sector”, and another states that the Employee Plans Team Audit (EPTA – Large Case) is expanding enforcement in “targeted risk areas, including international and abusive emerging issues”.

But what issues is the IRS referring to? In the attached memo, we discuss what the IRS is really interested in.


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