The grandfathered CAP privately held and/or grandfathered foreign owned taxpayer must submit audited U.S. GAAP annual financial statements to the CAP Program 90 days after the fiscal year end.
This requirement ensures that the financial statements are provided in a timely manner, allowing the IRS to review and resolve any tax compliance issues before the filing of the tax return. The submission of these audited financial statements is crucial for maintaining eligibility in the CAP Program, which aims to improve federal tax compliance through real-time issue resolution.
Sources:
Rev. Proc. 2023-17