The IRS has officially announced the opening of the application period for the 2026 Compliance Assurance Process (CAP), starting September 3, 2025, and closing October 31, 2025. This marks a key opportunity for large corporate taxpayers to gain pre-filing certainty on complex tax positions before their returns are filed.
For taxpayers and advisors, the CAP offers significant advantages:
However, entry into CAP is highly competitive and generally limited to the largest and most complex taxpayers, often with substantial international operations or transfer pricing risks.
For tax professionals, this means:
Tax professionals should act now to:
The CAP program continues to reflect the IRS’s shift toward collaborative compliance with the largest taxpayers an approach that may influence future mid-market audit strategies.
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