Yes. The bridge plus phase replaced the bridge phase for the 2024 CAP cycle and became permanent for the 2025 CAP cycle.
During the bridge phase, the IRS did not accept any disclosures, conduct any reviews, or provide any assurances. If there were specific issues a taxpayer wanted the IRS to consider, they could submit a request for a pre-filing agreement for these issues provided they met the requirements for a pre-filing agreement.
Our intent is not to open a bridge year for examination. However, there may be some limited circumstances where a Bridge year could be opened for examination. The items listed below may require consideration but do not automatically necessitate an examination:
- Any evidence of fraud, malfeasance, collusion, concealment or misrepresentation of a material fact
- Any new material issue not previously reviewed
- Any material changes to a previously reviewed issue
- Any material issue that was reserved for or reported on Schedule UTP during the bridge year
- Any material campaign issue
- Any clear arithmetic error or material error based on an established service position
- Any claim for refund that exceeds the Joint Committee on Taxation threshold
- Any other circumstances where a failure to open an examination would not be in the interest of tax administration