The WEIIC Practice Area serves the following taxpayers or stakeholders:

The WEIIC Practice Area is comprised of three program areas:

The goals of WEIIC align with the LB&I strategic goal to apply the tax laws with integrity and fairness through a highly skilled and satisfied workforce, in an environment of inclusion where each employee can make a maximum contribution to the mission of the team. Additionally, each program area aligned under WEIIC has its own program area level goals that supplement the WEIIC and LB&I level goals.

The Withholding and International Individual Compliance (WIIC) Practice Area stood up in February 2016. In November 2020, as part of a realignment of programs, WIIC added Exchange of Information responsibilities and changed its name to Withholding, Exchange and International Individual Compliance (WEIIC). This IRM chapter 4.63 is devoted to the WEIIC Practice Network program area focusing on Withholding and International Individual Compliance. Exchange of Information procedures are contained in IRM 4.60.1.

IRM 1.2.63, Division Delegations of Authority for Large Business and International provides authority relating to the Large Business and International Division.

IRM 1.2.2.5, Delegation of Authority for the Examining Process and IRM 1.2.2.6, Delegations of Authority for the Collecting Process.

IRM 4.10, Examination of Returns, provides the basic procedures, guidelines, and requirements for use by revenue agents and tax auditors in conducting income tax examinations. Additional procedures for LB&I cases are found in IRM 4.46, LB&I Examination Process.

IRM 4.10.21, U.S. Withholding Agent Examinations - Form 1042, provides basic concepts of U.S. source income which is subject to reporting and withholding under IRC 1441-1443 when paid to foreign persons. It also provides general guidance on examining Form 1042, Annual Withholding Tax Return of U.S. Source Income of Foreign Persons, with respect to nonresident alien (NRA) withholding.

IRM 4.60.1, Exchange of Information, provides guidance on sharing of tax related information between two or more countries for tax administration and enforcement.

IRM 4.63.2, LB&I WEIIC Practice Network Knowledge Management, describes practice network structure, the members and their respective roles and responsibilities as part of WEIIC.

IRM 4.63.3, Offshore Voluntary Disclosure Program, Streamlined Filing Compliance Procedures and Voluntary Disclosure Practice, includes information on the Streamlined Filing Compliance Procedures (Streamlined Procedures), the Offshore Voluntary Disclosure Program (OVDP) Transition, and the Voluntary Disclosure Practice (Post OVDP).

IRM 4.63.4, International Individual Compliance Examination Procedures, provides specific procedures, guidelines, and requirements for use by examiners in conducting income tax examinations on IIC cases.

IRM 4.64.1, Case Development and Processing Guidelines, provides authority, guidance, and procedures for the Central Withholding Agreement (CWA) program.

IRM 1.1.24, Large Business and International Division, contains the functional statements and responsibilities of the offices within the Large Business and International Division.

The WEIIC Director is responsible for the development, implementation and oversight of the foreign payments, international individual compliance, exchange of information, offshore compliance functions, and related supporting program initiatives.

Program Reports: The WEIIC Director prepares periodic briefing reports for the LB&I commissioner focusing on:

Program managers report progress on their respective program area level projects to the director of field operations, WEIIC practice area. Team managers provide progress reports on their team level projects to their respective program managers.

Program Effectiveness: The efficiency of WEIIC is measured through combined business results of the teams that comprise the WEIIC practice area.

The WEIIC Director is responsible for providing compiled director’s briefings for the LB&I commissioner to identify goals and accomplishments of each program area.

The table lists commonly used acronyms and their definitions:

For information regarding the WEIIC Practice Area international individual compliance strategies and program initiatives, refer to the WEIIC website https://irsgov.sharepoint.com/sites/LBI/Lists/LBIOrgs/DispItemForm.aspx?ID=16, LB&I Organizations - Withholding Exchange and International Individual Compliance (sharepoint.com).

For information regarding the Practice Networks (PN) structure, members and their respective roles and responsibilities, see IRM 4.63.2 , LB&I WEIIC Practice Network Knowledge Management.

For information regarding the International Individual Compliance (IIC) field operations structure, members and their respective roles and responsibilities, visit https://irsgov.sharepoint.com/sites/LBI/SitePages/ADCI212.aspx, International Individual Compliance (IIC) Field Operations (sharepoint.com).

For information regarding the Offshore Compliance Initiatives (OCI) structure, members and their respective roles and responsibilities, visit https://irsgov.sharepoint.com/sites/LBI/SitePages/ADCI31.aspx.

For information regarding the Foreign Payments Practice and Automatic Exchange of Information (FPP & AEOI) field operations structure, members and their respective roles and responsibilities, visit https://irsgov.sharepoint.com/sites/LBI/SitePages/ADCI211.aspx for FPP and https://irsgov.sharepoint.com/sites/ETD-KMT-KB110/SitePages/Locator%20Tools/FATCA/Guidance%20from%20AEOI%20Office.aspx for AEOI.

For information regarding the Exchange and Offshore Strategy Compliance (EOS) field operations structure, members and their respective roles and responsibilities, visit https://irsgov.sharepoint.com/sites/LBI/001/LB&I_Organization_Chart.pdf and https://irsgov.sharepoint.com/sites/LBI/SitePages/Global-LB&I-Information-Resources.aspx.

For information regarding the LB&I examination process, see IRM 4.46, LB&I Examination Process.

For information regarding the basic procedures, guidelines, and requirements used by revenue agents and tax auditors in conducting income tax examinations, see IRM 4.10, Examination of Returns.

To recommend changes or to make any other suggestions to this IRM section, contact the IRM author or see SPDER’s IMD Contacts list by referencing guidelines provided in IRM 1.11.6.5 , Providing Feedback About an IRM Section - Outside of Clearance. A request or inquiry can also be made at https://irsgov.sharepoint.com/sites/PolicyGateway/SitePages/Large-Business-and-International-Policy-Gateway.aspx

The EOI program administers and coordinates all exchanges of tax-related information between the U.S. and international jurisdictions under the provisions of international exchange agreements (including bilateral tax treaties, bilateral Tax Information Exchange Agreements (TIEAs), and multilateral exchange treaties and agreements), except for:

Other responsibilities of EOI include:

For more information on the EOI Program, please see IRM 4.60.1, Exchange of Information.

The Offshore Compliance Initiatives (OCI) office promotes voluntary compliance with U.S. tax and foreign information reporting laws through strategic enforcement actions directed at identifying U.S. taxpayers involved in abusive offshore tax schemes. In addition, OCI focuses on banks, other financial institutions and third parties that provide, facilitate, or enable offshore financial arrangements and structures. OCI also conducts information gathering and data analysis activities to identify promoters or facilitators of abusive offshore schemes for compliance activities, participates in international forums for improving voluntary compliance, sharing best practices, and leveraging resources, focuses on taxpayers who did not report offshore activity through application of tax treaties and provides technical and procedural guidance on international issues associated with offshore arrangements.

OCI also includes the Joint International Taskforce on Shared Intelligence and Cooperation (JITSIC). JITSIC is a global network of national tax administrations, facilitating, and operationalizing the sharing of intelligence and working together to tackle operational risks in tax administration focusing on abusive transactions.

The WEIIC Inbound and Outbound Practice Networks (PN) develop campaigns and provide training and technical support for field teams on individual inbound and outbound transactions as well as transactions involving digital assets.

The WEIIC PN office focuses on compliance issues related to international individual outbound transactions and international individual inbound transactions as well as transactions involving digital assets.

The WEIIC Practice Area includes the following PNs:

Planning and Special Programs (PSP) is responsible for the identification, classification, risk assessment, and return delivery of the IIC filing population. It supports the field teams with inventory and workflow by monitoring actual performance against the compliance plan and providing updates and status reports necessary to allocate time and resources properly. PSP responsibilities include: