News & Analysis as of

Defending Federal and State Tax Audits For High-Income Taxpayers

In 2013 the IRS audited slightly over one taxpayer in nine[1] with an income of $1 million or more.[2] This audit rate represents a sharp 69 percent increase from the 6.42 percent audit rate that similar high-income...more

Focus on Tax Controversy - Spring 2014

Company Jet Audit Issues: A Word to the Wise - Once a business attains a certain level of success, an aircraft often becomes a valued asset. Public and closely held private companies alike find that the use of a...more

Estate Tax Audits for Large Estates Are a Virtual Certainty

What you need to know: Recent audit statistics show that federal estate tax returns are facing increased scrutiny from the IRS....more

IRS Releases Its “Roadmap” Of The Transfer Pricing Audit Process

The US Internal Revenue Service has released its Transfer Pricing Audit Roadmap, a 26-page outline of the two-year transfer pricing audit process, emphasizing up-front planning and a fact-based approach for examiners. ...more

Tax Traps of Employment Documents [Video]

IRS employment tax audits are rising and as such, it’s important for employers to understand what to look for in their employee benefit programs to avoid any adverse tax findings. This brief video outlines some of the most...more

Transfer Pricing Audit Roadmap

Code Section 482 requires that transactions between related companies be conducted based on “arms-length” pricing. The purpose of the section is to foreclose inappropriate pricing methods that attempt to shift profits to...more

A Retirement Plan Sponsor’s Guide for Selecting Their Financial Advisor

When it comes to your role as a retirement plan sponsor, outside of hiring a TPA (third party administrator), the most important plan provider that you need to hire is a financial advisor. Unfortunately, like my favorite...more

Mistakes a Plan Sponsor Should Correct Before an IRS/DOL Audit

I have been in the retirement plan business for over 15 years and I have met too many plan sponsors who don’t care that their plan isn’t being run correctly. What makes them eventually care is when they are audited by the...more

Treasury Inspector General Report on 1603 Cash Grant Seems Off the Mark

On December 17, the Treasury Inspector General for Tax Administration released Review of Section 1603 Grants in Lieu of Energy Investment Tax Credit which is available below. Either there is some confusion associated with the...more

New Mandatory Enforcement Process For Information Document Requests in Large Business and International Tax Examinations

On January 2, 2014, the Large Business & International (“LB&I”) Division of the Internal Revenue Service began using a new mandatory enforcement process for delinquent information document requests (“IDRs”) in tax...more

Is Your Tax Return Being Audited? Know What To Do!

For most people, when their income tax returns are being selected for examination by the IRS, their first reaction is panic. No need to worry. In such a situation, you should know what to do next, what to expect next, and...more

IRS “Wealth Squad” – Something to Keep in Mind During Tax Season

The IRS Global High Wealth Industry (“GHWI”) (part of the IRS Large Business & International Division) is auditing individuals with tens of millions of assets or income who utilize complicated financial and estate plan...more

Nonprofit Law Revitalization Comes to New York

On December 18, 2013, New York Governor Andrew Cuomo signed into law the Nonprofit Revitalization Act of 2013 which modernizes the New York nonprofit corporation law. The Act overwhelmingly passed both houses of the New York...more

By The Book - August 2013: IRS Report Scrutinizes Unrelated Business Income Reporting by Tax-Exempt Organizations

The Internal Revenue Service (IRS) has released a final report (the “Report”) summarizing its findings from a study focused on the level of compliance by tax-exempt colleges and universities with respect to unrelated business...more

Right from the Source: IRS Guidance for U.S. Plan Sponsors on Fixing Mistakes and Surviving IRS Employee Plan Audits

Those of you who participated in our July 16 webinar on plan fix-it programs heard us emphasize the importance of self-audits and internal controls to increase your chances of coming out clean in an employee plan audit....more

Compliance Corner: Review of IRS 2013 Audit Priorities

Although the Internal Revenue Service (IRS) is engaged in a variety of ongoing qualified plan compliance, education and audit projects, it is targeting certain types of retirement plans and activities in 2013....more

“Breaking Bad” And Tax Evasion

I love the TV Series “Breaking Bad” on AMC. In a nutshell, it is about a tough luck high school chemistry teacher named Walter White who turns into a major drug dealer and murderer. ...more

Introducing the "Compliance Corner"

Several governmental agencies, including the Internal Revenue Service (IRS), Department of Labor (DOL), Securities and Exchange Commission (SEC) and Department of Health and Human Services (HHS), have stepped up their audit...more

June 30 Deadline to Apply for Temporary Employment Tax Settlement Program

Is your company considering reclassifying certain workers, but hesitant because it is worried about triggering a federal employment tax audit or not having consistently filed Form 1099s for those workers in the past? If you...more

U.S. Plan Audit Activity is on the Rise – How to Lower Your Risk

Does your 401(k) plan pay higher than average fees? Do you have more than one qualified plan? A number of recent reports indicate why you may receive special scrutiny if your plan is selected for audit or...more

Focus - Spring 2013

In This Issue: - IRS Audits: Understanding Criminal Rights and Risks - Amazing Clients®: Ravago: A Big Company with a Low Profile - When is a Mom not a Mom?: De Facto Parenting in Massachusetts - Can the...more

IRS Goes Back 41 Years To Assess Gift Tax

If a taxpayer does not file a tax return, the statute of limitations for most federal taxes never commences. Thus, in theory, the IRS can go back as many years it wants to such an “open” year to audit and assess tax....more

IRS Issues Wake Up Call to Colleges and Universities — Congress to Hold Hearings

The IRS released its Final Report on its five year study of the audit results of colleges and universities. Lois G. Lerner, Director of the Exempt Organizations division of the IRS announced the “long awaited” posting of the...more

Compensation and Unrelated Business Income are Focus of IRS Colleges and Universities Report

Just a few weeks before many tax-exempt organizations file their annual Form 990, the IRS yesterday released its final report on the Colleges and Universities Compliance Project, which it had initiated in 2008 by sending...more

IRS Pressures Build: Budgetary Constraints, the Aging IRS Workforce and Changes in IRS Focus

On April 10, 2013, President Obama released his proposed Fiscal Year 2014 Budget of the U.S. Government. The budget calls for an increase in funding for the Internal Revenue Service (“IRS”), which has faced budget cuts in...more

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