The US Internal Revenue Service has opened applications for the 2027 Compliance Assurance Process, allowing eligible large corporations to resolve tax compliance issues cooperatively with the IRS before filing their returns.
The US Internal Revenue Service (IRS) announced on 8 September 2026 the opening of applications for the 2027 Compliance Assurance Process (CAP) programme, with submissions due by 30 October 2026.
Notification of acceptance decisions will follow in February 2027.
Real-time issue resolution for large corporations
Since its 2005 launch, CAP has enabled major corporate taxpayers to resolve tax matters cooperatively with the IRS before filing returns. The programme identifies and addresses compliance issues early, offering corporations greater certainty while allowing the IRS to concentrate its examination resources more efficiently.
Who can apply
Applicants must satisfy three core requirements. First, the corporation must maintain at least AUD 10 million in assets. Second, it cannot be the subject of government investigation or litigation that would restrict the IRS’s access to current tax records.
Third, the applicant must meet one of two financial documentation standards. US publicly traded corporations must prepare SEC Forms 10-K (annual), 10-Q (quarterly), and 8-K (current report) as required by law.
Alternatively, privately held C corporations, including foreign-owned entities, may participate by submitting audited annual financial statements prepared under US Generally Accepted Accounting Principles (GAAP), International Financial Reporting Standards (IFRS), or another IRS-approved methodology. These audited statements require an unqualified opinion from an independent auditor and must reconcile to Schedule M-3 line 4(a) worldwide consolidated net income or loss. Quarterly unaudited statements are also required.
Additional programme details and 2027 application materials are available on IRS.gov under the CAP programme section.
