TEB administers the Voluntary Closing Agreement Program (TEB VCAP) to assist governmental issuers in resolving violations of the federal tax laws applicable to their tax-exempt bonds, tax credit bonds, or direct pay bonds (tax-advantaged bonds). Under TEB VCAP, issuers can conclusively resolve violations through the execution of closing agreements with the IRS. The primary objective of TEB VCAP is to encourage issuers and other parties to bond transactions to exercise due diligence in complying with applicable federal tax laws and to provide a vehicle to correct tax violations as expeditiously as possible. As such, unlike private letter rulings, closing agreements under TEB VCAP may not conclusively resolve matters of tax law relating to future events or actions impacting the tax-advantaged status of bonds. IRM 7.2.3 provides procedures for TEB VCAP. Links to the various sections of this IRM relating to submission requests and case processing are organized below. Objective and general matters These IRM procedures provide general information about the objectives and scope of TEB VCAP. They also provide general information about the effect of closing agreements, how TEB VCAP impacts the selection of bond issues for examination, and special procedures for anonymous requests. IRM 7.2.3.1 – 7.2.3.1.4 TEB VCAP Objectives, Scope and Other General Matters IRM 7.2.3.1.5 Effect of TEB VCAP Closing Agreement IRM 7.2.3.1.6 Audit of TEB VCAP Cases IRM 7.2.3.1.7 Special Procedures for Anonymous Requests How to submit a request for VCAP You must include a model closing agreement with your submission. These IRM procedures describe the information required to be provided by the issuer in its TEB VCAP submission request as well as the case assignment procedures. IRM 7.2.3.2 – 7.2.3.2.1 Information Required in Submission Request IRM 7.2.3.2.2 Receipt and Perfection of Submission Request Case resolution and closing Read about standards used in resolving TEB VCAP cases. These IRM procedures describe the process for the resolution and closing of TEB VCAP cases. IRM 7.2.3.3.3 – 7.2.3.3.4 Case Resolution and Closing Agreement Execution IRM 7.2.3.3.5 Case Closing IRM 7.2.3.3.6 Unresolved Cases
