The IRS opens applications for the 2027 Compliance Assurance Process until 30 October 2026. The programme aims to identify and resolve tax issues with a business before it files its return; the IRS announces admission notifications in February 2027.
Applicants must, in particular, have at least 10 million dollars in assets and not be under investigation or litigation limiting IRS access to current tax records. The programme covers certain US publicly traded companies and certain privately held C corporations, under different documentation requirements.
The application can be examined for continuity of information: annual accounts, quarterly statements and tax reconciliation should be explainable together. Meeting an asset threshold does not compensate for unavailable documentation or an obstacle to IRS access. The cooperative approach therefore requires the ability to discuss tax issues before filing; it is not advance approval of every position the business might subsequently adopt.
For the latter companies, the commitment to provide audited annual statements and quarterly statements is more than an application formality. The audit opinion must be unqualified and the result reconciled to Schedule M-3. All admission conditions still need to be checked; submitting a file guarantees neither acceptance nor the outcome of a tax issue.