CAP phase and Compliance Maintenance phase taxpayers provide CBAQs according to the schedule below. Initial CBAQ A taxpayer must submit the initial CBAQ within 90 days of the end of the prior tax year based on its projections for the CAP year. If the initial CBAQ necessitates the use of tax provision estimates, notate this on the form. The initial CBAQ information will be used to begin the risk assessment process for the current CAP year. For example, a calendar year end taxpayer in CAP for 2025 must provide an initial CBAQ by March 31, 2025. This CBAQ will be used for the initial risk assessment for the 2025 CAP year. Interim CBAQ (if necessary) An interim CBAQ must be submitted within 30 days of the completion of any material transaction or activity identified in the CBAQ. The interim CBAQ is required to report information only with respect to updates to the relevant transactions. Also, to the extent any question on the CBAQ related only to the CAP year and was noted on the Initial CBAQ as “to be determined,” the interim CBAQ should be updated for the taxpayer’s response within 30 days of the taxpayer acquiring the information necessary to respond. For example, if a material new transaction occurs on June 10, 2025, an interim CBAQ reporting this transaction must be submitted by July 10, 2025. Final CBAQ A taxpayer must submit a final CBAQ when the tax return for the CAP year is filed. This CBAQ will facilitate the team’s post-filing review. For example, on October 15, 2026, a calendar year end taxpayer files Form 1120 with respect to the 2025 tax year. The taxpayer submits the final CBAQ for the 2025 CAP year on October 15, 2026. This will be used to complete the post-filing review of the 2025 CAP year. Note: Your participation in the CAP program may be at risk if you: Submit a CBAQ after the due date without an approved extension from the case and issue territory manager Submit an inaccurate or incomplete CBAQ We treat these as significant or material failures to adhere to the CAP MOU terms.
