The CAP Memorandum of Understanding (MOU) is a standardized document used in the Compliance Assurance Process (CAP) Program, which includes three phases: CAP, Compliance Maintenance (CM), and Bridge. The annual CAP MOU sets forth the expectations and requirements for both the taxpayer and the IRS. The only variable elements in the MOU are the taxpayer's name, Employer Identification Number (EIN), and the tax year. The MOU is designed to facilitate real-time issue resolution and improve federal tax compliance by resolving issues before the filing of the tax return.
Sources:
Rev. Proc. 2024-1
IRM Part 4. Examining Process. Chapter 60. International Procedures. Section 11. International Compliance Assurance Program
IRM Part 4. Examining Process. Chapter 46. LB&I Examination Process. Section 5. Resolving the Examination
