The challenges of the Compliance Assurance Process (CAP) Program include:
- Resource Constraints: Limited resources can impact the timely resolution of issues, potentially delaying the process.
- Adversarial Relationships: A reluctance to view the other party as a partner and to adopt a less adversarial approach can elongate the process.
- Aggressive Timelines: The timelines set for resolving issues may not always align with the complexity of the issues at hand.
- Multiple Open Tax Years: Due to the complexity of certain issues, taxpayers may have more than one open filed tax year and one open unfiled tax year when the new CAP year begins.
Sources:
IRM Part 8. Appeals. Chapter 26. Alternative Dispute Resolution (ADR) Program. Section 8. Compliance Assurance Process - Fast Track Settlement
IRM Part 4. Examining Process. Chapter 60. International Procedures. Section 11. International Compliance Assurance Program
