A Closer Look at the IRS Large Business and International Division

By Holly Paz, Acting Commissioner, Large Business & International

CL-23-01, January 5, 2023

As Acting Commissioner of Large Business and International (LB&I), I have the privilege of leading 4,615 employees in 215 office sites. I’m very proud to work for the IRS and of the work that we do. As the inscription on the entrance to the IRS headquarters states, “Taxes are what we pay for a civilized society.” It’s a quote by former Supreme Court Justice Oliver Wendell Holmes. And it’s true.

The IRS has no shortage of very interesting work. Within the agency and within the division I lead, it’s possible to have many different jobs – in tax and outside of tax – and still have the stability and consistency of a long-term IRS career. In the private sector, this type of variety or reinvigoration may only be possible by changing employers. In over 15 years of experience at the IRS, I have worked in the Taxpayer Advocate Service, in Exempt Organizations and in areas ranging from corporate issues and credits to partnerships in LB&I.

In this column, I’m taking “A Closer Look” at the LB&I division. LB&I conducts tax administration activities for domestic and foreign businesses with a U.S. tax reporting requirement and assets equal to or more than $10 million. We also manage the Global High Wealth and International Individual Compliance programs. When people think of LB&I, audits of large companies likely come to mind, but there is much more. LB&I serves a unique role in U.S. tax administration with our work in world-wide engagement and our role as U.S. Competent Authority (legal designee over bilateral agreements between the U.S. and our treaty partners) and the programs under that authority.

As you would expect, LB&I has many employees with backgrounds in accounting and finance, but our workforce is made up of employees from many backgrounds. You may be surprised to know that we also provide careers for lawyers, economists, actuaries, data scientists and engineers, as tax administration requires skills from a variety of disciplines.

We operate as a team to ensure taxpayer compliance. Most of our technical employees in LB&I have responsibility for oversight of our taxpayer base of large business (both corporate and passthroughs) as well as some individuals. Our core work is led by revenue agents, who are generally accountants, with support from employees with a variety of expertise, including lawyers, economists, actuaries, subject matter experts, appraisers and others. Our work selection is driven by data analysis and sophisticated compliance models. In addition to this work, which is more in line with other divisions of the IRS, LB&I has some unique work highlighted below.

Competent Authority

The United States has tax treaties with 60 countries and 58 of those treaties are currently in force. As Acting LB&I Commissioner, I serve as the U.S. Competent Authority, which means I oversee the organization’s engagement in multilateral, multinational tax administration. LB&I’s Competent Authority role is of paramount importance to tax administration, as we help taxpayers avoid double taxation.

Helping taxpayers achieve a fair result is a responsibility we take seriously. We work with our treaty partners to get to the right answer, recognizing the various interests at play. Our goal is to ensure the most principled results – not the result that produces the maximum amount of revenue for the country. Most of our work in this area is done by front-line employees who are experts in these issues.

World-Wide Engagement

LB&I manages the overall IRS relationship with the Organisation for Economic Co-operation and Development (OECD) and its subgroup Forum on Tax Administration (FTA). The OECD is an intergovernmental economic organization; its 38 member countries work together to stimulate economic progress and world trade. The FTA brings together the commissioners of 50 global tax administrations in a forum wherein they identify, discuss and influence relevant global trends and work to increase fairness and effectiveness across all agencies. A continued focus of this work is tax certainty for global taxpayers, which is related to many Competent Authority programs under LB&I oversight.

Exchange of Information

LB&I is responsible for both the Exchange of Information (EOI) and Automatic Exchange of Information (AEOI) programs. Exchange of information refers to the sharing of tax-related information for tax administration and enforcement purposes.

Our EOI programs generally deal with exchanges of tax-related information between national tax authorities that occur under the provisions of international tax information sharing agreements, including treaties and tax information exchange agreements (TIEAs). Tax authorities rely on global collaboration to implement international standards of transparency and effective EOI for tax purposes.

Joint International Taskforce on Shared Intelligence and Collaboration

LB&I houses the Joint International Taskforce on Shared Intelligence and Collaboration (JITSIC), a multi-country workgroup that addresses cross-border tax avoidance schemes, transactions and structures. The JITSIC network consists of tax administrations from more than 40 jurisdictions, all member countries in the OECD Forum on Tax Administration.

LB&I’s JITSIC team coordinates FTA JITSIC network projects, joint collaborations, and analysis and coordination of risks identified in the OECD Aggressive Tax Planning (ATP) Directory.

Strength Through Professionalism and Teamwork

Our work can be challenging, but the challenges are what make the job rewarding. It’s also very gratifying to have a job where the goal is to find the right answer. While we represent the government’s interest, we strive to do so in a way that’s fair to taxpayers and efficient for the country’s tax administration. LB&I’s talented, dedicated employees are helping people understand and meet their U.S. tax responsibilities and fairly and reliably enforce U.S. tax law.

Professionalism, pride in public service, and dedication to the IRS's mission are values and traits common within LB&I. They’re shared by LB&I’s frontline employees directly involved in tax-related casework and by our employees whose roles in planning and policy, information technology, administration, training, human capital, and communications support their counterparts in the field.

I hope this gives you a greater understanding of some of our core work and how we accomplish it. The IRS is currently working toward a unified compliance organization that brings our work together with business divisions that serve other taxpayer sectors, such as small businesses, self-employed, and individual non-business filers. This will not only improve our internal coordination and our service to taxpayers; it will also create more opportunities for those seeking a rewarding career in America’s tax administration.

There is so much more to LB&I’s portfolio of programs than I could include in this article. You can learn more about how the LB&I workforce serves our diverse taxpayer base by visiting LB&I’s?At-a-Glance webpage . If you’d like to join the LB&I team, see our open opportunities on?USAJOBS .

Holly Paz

Acting Commissioner, Large Business and International

A Closer Look