On 4 May 2016, the U.S. IRS issued Revenue Procedure 2016-30, which modifies and supersedes Revenue Procedure 2009-14. The procedure permits a taxpayer under the jurisdiction of the Large Business and International Division (LB&I) to request that the IRS examine specific issues relating to tax returns before those returns are filed. The revenue procedure provides the framework within which a taxpayer and the IRS may work together in a cooperative environment to resolve, after examination, issues accepted into the program. If the taxpayer and the IRS are able to resolve the examined issues before the tax returns that they affect...