News & Analysis as of

Audits Internal Revenue Service Partnerships

Foodman CPAs & Advisors

IRS Use of AI Can Close Tax GAP

On 10/12/23, the IRS announced new tax gap projections for tax years 2020 and 2021 showing the projected gross tax gap increased to $688 billion in tax year 2021, a rise of more than $192 billion from the prior estimates for...more

Latham & Watkins LLP

IRS Launches New Large Partnership Audits, Relying on AI and Increased Funding

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The IRS is making good on its promise to step up enforcement on large partnerships that issue more than 100 annual K-1s and have more than $100 million in assets. As noted in this Latham Client Alert, the IRS’s renewed focus...more

Allen Barron, Inc.

You Sign Every Tax Return Under The Penalties of Perjury

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Many Americans have not noticed the paragraph above their signature line on the 1040 and other IRS and state tax forms, which notifies the taxpayer that they signed their tax return "under the penalties of perjury" and that...more

Holland & Knight LLP

IRS Targets Owners of Professional Sports Franchises Regarding Tax Reporting

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Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more

Farella Braun + Martel LLP

The IRS Is Targeting Partnership Transactions: Is Your Representative Ready?

Earlier this week, Treasury and the IRS issued guidance to halt the use of partnership rules in the Internal Revenue Code to engage in abusive basis-shifting transactions whereby tax basis is stripped from certain assets and...more

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

Holland & Knight LLP

Tax Court: IRS Must Adhere to BBA Regulations' Plain Language

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The U.S. Tax Court recently held in SN Worthington Holdings LLC v. Commissioner, 162 T.C. No. 10 (2024), that the petitioning partnership had properly elected into the Bipartisan Budget Act of 2015 (BBA) procedures for the...more

McDermott Will & Emery

IRS Announces New Audit Initiative Focused on Jet Airplane Usage

On February 21, 2024, the Internal Revenue Service (IRS) announced a new initiative to audit the use of airplanes by corporations, large partnerships and high-net-worth individuals. While the IRS has always examined plane...more

Husch Blackwell LLP

Increased IRS Scrutiny on Use of Personal and Business Aircraft

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On February 21, 2024, the Internal Revenue Service (IRS) announced plans to conduct dozens of audits on the use of business aircraft by large corporations, partnerships, and high-income individuals as part of its “campaign”...more

Rivkin Radler LLP

Partnership Losses on Related Party Sales – The IRS Provides Some Clarification

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Few individual owners of a closely held business would be surprised if you explained to them that the IRS and the Federal courts generally will subject many transactions between certain “related” persons to heightened...more

Latham & Watkins LLP

New IRS Unit Leverages AI to Step Up Partnership Audits; Hundreds of New Inquiries Expected

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The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more

Allen Barron, Inc.

How Does the IRS Use AI to Identify Tax Cheats?

Allen Barron, Inc. on

Could Artificial Intelligence (AI) increase the likelihood of an IRS audit in your future? How does the IRS use AI to identify US taxpayers who attempt to hide assets, under-report income or otherwise cheat the IRS? In...more

Warner Norcross + Judd

The IRS is Shifting Audit Attention to Large Partnerships and Wealthy Individuals

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In 2009, the IRS created its Global High Wealth Industry Group, known more familiarly as the “Wealth Squad.” This group starts with an examination of a “key case,” which is typically a wealthy person’s individual tax return,...more

Foodman CPAs & Advisors

Inteligencia Artificial Asiste Al IRS Con Los Evasores De Impuestos

El 20/09/23, el IRS anunció que planea establecer un área especial para centrarse en entidades de transferencia grandes o complejas para ayudar con los esfuerzos de cumplimiento de altos ingresos. Con la ayuda de tecnología...more

Foodman CPAs & Advisors

Artificial Intelligence To Assist IRS With Tax Cheats

On 9/20/23, the IRS announced that it plans to establish a special area to focus on large or complex pass-through entities to help with high-income compliance efforts. With the assistance of improved technology as well as...more

Foodman CPAs & Advisors

IRS Y Sus Nuevos Esfuerzos De Cumplimiento

Foodman CPAs & Advisors on

En 9/8/23, el IRS anunció nuevos esfuerzos de cumplimiento que se centrarán en aumentar el escrutinio de los contribuyentes de altos ingresos/altos patrimonios, sociedades, corporaciones y promotores que abusan de las normas...more

Skadden, Arps, Slate, Meagher & Flom LLP

The IRS Is Coming for Partnerships and High Net Wealth Individuals

The Internal Revenue Service plans to deploy thousands of new hires to expand audits of partnerships and high net wealth individuals. As part of a larger transformation at the agency, it is using some of the $60 billion in...more

Foodman CPAs & Advisors

New IRS Compliance Efforts

On 9/823, the IRS announced new compliance efforts that will focus on increasing scrutiny on high-income taxpayers, partnerships, corporations and promoters abusing tax rules on the books by using Artificial Intelligence and...more

Allen Barron, Inc.

IRS Focuses Scrutiny on High-Income Taxpayers, Partnerships and Corporations

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New issues come into focus as the IRS focuses scrutiny on high-income taxpayers, partnerships and corporations, as well as those who promote the abuse of tax rules.  The IRS has formally given notice that it intends to...more

Vinson & Elkins LLP

The Heat Is on for Large Partnership Audits

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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

Holland & Knight LLP

IRS Announces Sweeping Enforcement Effort Targeting Partnerships

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The IRS announced a "sweeping" and "historic" enforcement effort focused on partnerships and is establishing a special group within its Large Business and International (LB&I) Division to focus exclusively on large and...more

Kohrman Jackson & Krantz LLP

Artificial Intelligence Allows IRS to Increase Scrutiny of High-Earners & Partnerships

The Internal Revenue Service (IRS) recently announced a renewed effort to ensure compliance with federal tax law, specifically focusing on high-income earners, partnerships, and large corporations. This additional scrutiny...more

McDermott Will & Emery

IRS Strengthens Its Large Partnership Audit Teams

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Back in October 2021, the Internal Revenue Service’s (IRS) Large Business and International (LB&I) division announced the Large Partnership Compliance (LPC) program. This new audit program adopted features of the Large...more

Fox Rothschild LLP

IRS Going All in on Use of ArtificiaI Intelligence

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The IRS issued a news release today announcing a continued and more focused use of Artificial Intelligence (AI) to audit partnerships, large corporations and alleged tax shelter promoters. The news release follows...more

Holland & Knight LLP

IRS Partnership Audits: 5 Must-Dos in 30 Days

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With the IRS laser-focused on enforcement, many partnerships will find themselves subject to their first IRS audits under the new procedurally complex partnership audit rules. Under these rules, the default is that the...more

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