News & Analysis as of

Audits Internal Revenue Service Enforcement

Allen Barron, Inc.

What is the “Abusive Use of Partnerships” and Why does the IRS Care?

Allen Barron, Inc. on

What is now considered as the “abusive use of partnerships,” and why would this matter to the IRS? The agency recently released IR-2024-166, which is intended to provide “new guidance to stop partnerships from using...more

ArentFox Schiff

Fixing a Hole: IRS to Use AI and IRA Funds to Bolster Tax Enforcement

ArentFox Schiff on

The Inflation Reduction Act (IRA), enacted in August 2022, appropriated billions of dollars in additional funding to the Internal Revenue Service (IRS). The IRS has begun allocating funds, including investing in artificial...more

Vinson & Elkins LLP

The Heat Is on for Large Partnership Audits

Vinson & Elkins LLP on

Large partnerships are facing a sea change in tax enforcement. Beginning with the Large Partnership Compliance program announced in 2021 and its most recent announcement that it intends to “stand up” a group focused on large...more

Levenfeld Pearlstein, LLC

IRS’s Plan Includes Increased Audits for Corporate and High-Income Taxpayers

On April 6, 2023, the Internal Revenue Service released its much-anticipated strategic operating plan. The plan outlines how the agency will use the additional $80 billion in funding from the Inflation Reduction Act. Of...more

Alston & Bird

IRS Prioritizes Enforcement Against High-Wealth Taxpayers in the Inflation Reduction Act Strategic Operating Plan

Alston & Bird on

The Inflation Reduction Act Strategic Operating Plan, released last week by the Internal Revenue Service, envisions a future of increased audits and penalties for family offices, high-wealth individuals, large partnerships,...more

Skadden, Arps, Slate, Meagher & Flom LLP

Tax Enforcement: A Spotlight on Complex Partnership Structures

The boost in funding for the Internal Revenue Service (IRS) provided in the Inflation Reduction Act of 2022 (IRA) comes just as it has started rolling out in earnest programs focusing on auditing complex partnership...more

Husch Blackwell LLP

Inflation Reduction Act to Greatly Increase IRS Funding

Husch Blackwell LLP on

The Inflation Reduction Act of 2022 (IRA) includes increased Internal Revenue Service (IRS) funding in the amount of approximately $80 billion over ten years. According to a Congressional Research Service report, the law...more

White and Williams LLP

2022 Tax Filing Season: Nine Things You Need to Know

White and Williams LLP on

The 2022 tax season is upon us. With what promises to be an unusual tax filing season, below are nine updates and tips to keep in mind. 1. Tax Returns are Lagging. On January 12, the National Taxpayer Advocate issued its...more

Morrison & Foerster LLP

The Impending Large Partnership Audits

In August, the Federal Bar Association Section on Taxation held an informative roundtable on the IRS’s new large partnership compliance or LPC program. One of the speakers, Maria Dolan with the IRS’s Large Business &...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

Rivkin Radler LLP on

Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Vinson & Elkins LLP

IRS Enforcement Revival: Could The Long Decline In Criminal And Fraud Enforcement Activity Be Coming To An End?

Vinson & Elkins LLP on

In his April 28, 2021 address, President Biden asked Congress to provide $80 billion of extra funding for the Internal Revenue Service (“IRS”) over the next decade. While the timing and amount of any additional funding are...more

Katten Muchin Rosenman LLP

The SEC's MCDC Initiative: Where To Go From Here

Issuers, underwriters and advisors in the municipal bond marketplace are facing unprecedented challenges from federal regulators in connection with both the issuance of bonds and ongoing post-issuance compliance. These...more

Skadden, Arps, Slate, Meagher & Flom LLP

"Executive Compensation and Benefits Alert: IRS Section 409A Audit Initiative May Signal Increased Enforcement Activity"

Since the adoption of Section 409A of the Internal Revenue Code, employers and practitioners have wondered when and how the IRS would enforce it. With the recent IRS announcement of an audit initiative with respect to Section...more

King & Spalding

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

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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

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