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IRS announces the end of the AOF IDR process and other changes to expedite LB&I exams
ARTICLE | July 29, 2025
Authored by RSM US LLP
Executive summary
On July 23, 2025, the IRS announced several changes aimed at speeding up the Large Business and International (LB&I) examination process.
On July 23, 2025, the IRS announced several changes aimed at speeding up the Large Business and International (LB&I) examination process. It plans to discontinue the Acknowledgement of Facts Information Document Request (AOF IDR) process by 2026 for Large Business and International examinations. In the lead up, the IRS will allow taxpayers currently under examination and those with new exams to decide whether to use the process or not. The IRS explained it was making this change in recognition of feedback from taxpayers that the AOF IDR process was adding needless time to examinations. This is a welcome change for taxpayers engaged in LB&I examinations as the AOF IDR process was time consuming and resource intensive.
RSM US’ Tax Controversy professionals are skilled in evaluating the circumstances of each examination and are equipped to advise taxpayers in examination whether to opt into the AOF IDR process. Depending on the issues present in the case, the process may be beneficial or disadvantageous.
In addition to ending the AOF IDR process, the IRS also announced edits to the Internal Revenue Manual to make it clear that Accelerated Issue Resolution (AIR) is available to all Large Corporate Compliance (LCC) cases. While this is a great avenue for some taxpayers, it may not always be the best option depending on the particular circumstances. There are factual, legal, and cost considerations in deciding whether to use this option.
One thing for taxpayers to consider under the advice of a skilled tax controversy professional is that the application of Federal Rule of Evidence (FRE) 408 to the Fast Track Appeals process. Federal Rule of Evidence 408 prohibits the introduction of evidence concerning settlement discussions in a court proceeding. If a taxpayer intends to dispute a tax deficiency all the way through litigation, it may be important to consider what is shared during the Fast Track Appeals process since the FRE 408 does not apply to statements made to the IRS during the Examination process. It would be prudent to consult with a tax controversy specialist like those in RSM’s Tax Controversy practice.
Please connect with your advisor if you have any questions about this article.
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This article was written by Alina Solodchikova, Marissa Lenius and originally appeared on 2025-07-29. Reprinted with permission from RSM US LLP.
© 2024 RSM US LLP. All rights reserved. https://rsmus.com/insights/tax-alerts/2025/irs-announces-the-end-of-the-aof-idr-process-and-other-changes-to-expedite-lb-i-exams.html
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The information contained herein is general in nature and based on authorities that are subject to change. RSM US LLP guarantees neither the accuracy nor completeness of any information and is not responsible for any errors or omissions, or for results obtained by others as a result of reliance upon such information. RSM US LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect information contained herein. This publication does not, and is not intended to, provide legal, tax or accounting advice, and readers should consult their tax advisors concerning the application of tax laws to their particular situations. This analysis is not tax advice and is not intended or written to be used, and cannot be used, for purposes of avoiding tax penalties that may be imposed on any taxpayer.
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