This article is the third in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the...more
4/17/2026
/ Appeals ,
Filing Deadlines ,
Innocent Spouse Exception ,
Internal Revenue Code (IRC) ,
IRS ,
Judicial Review ,
Jurisdiction ,
New Legislation ,
Penalties ,
Proposed Legislation ,
Subpoenas ,
Tax Appeals ,
Tax Court ,
Tax Credits ,
Tax Legislation ,
Tax Liability ,
Tax Litigation ,
Tax Refunds ,
Taxation
This article is the second in a series analyzing the proposed Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the...more
4/13/2026
/ Cross-Border Transactions ,
Currency Exchange ,
FBAR ,
FinCEN ,
Foreign Bank Accounts ,
GAO ,
Income Taxes ,
International Tax Issues ,
IRS ,
New Legislation ,
Proposed Legislation ,
Reporting Requirements ,
Tax Credits ,
Tax Legislation ,
Taxation
This article is the first in a series of articles analyzing the Taxpayer Assistance and Service Act (the “TAS Act”), bipartisan legislation introduced by Senators Crapo and Wyden to improve service and administration at the...more
4/10/2026
/ Electronic Filing ,
Filing Requirements ,
Government Agencies ,
IRS ,
New Legislation ,
Offer-in-Compromise ,
Process Improvement ,
Proposed Legislation ,
Reporting Requirements ,
Tax Legislation ,
Tax Liability ,
Tax Reform ,
Tax Returns ,
Taxation ,
Transparency
On February 26, 2026, Senate Finance Committee Chairman Mike Crapo (R-Idaho) and Ranking Member Ron Wyden (D-Oregon) introduced the Taxpayer Assistance and Service Act, a bipartisan legislative package proposing significant...more
4/6/2026
/ Appeals ,
IRS ,
Judicial Review ,
New Legislation ,
Proposed Legislation ,
Refunds ,
Small Business ,
Tax Appeals ,
Tax Court ,
Tax Legislation ,
Tax Penalties ,
Tax Reform ,
Tax Refunds ,
Tax Returns ,
Taxation ,
U.S. Treasury ,
Whistleblowers
In the wake of a March 9 letter from three U.S. Senators expressing concerns about Treasury Secretary Scott Bessent’s dual role as Acting IRS Commissioner, the IRS announced today that Bessent is no longer serving as Acting...more
3/16/2026
/ Appointments Clause ,
Congressional Oversight ,
Federal Vacancies Reform Act ,
Government Agencies ,
IRS ,
Presidential Appointments ,
Presidential Nominations ,
Regulatory Oversight ,
Senate Confirmation Hearings ,
Statutory Requirements ,
Taxation ,
U.S. Treasury
The Internal Revenue Service has unveiled a new web page on IRS.gov that allows taxpayers to confidentially report suspected tax fraud or evasion, scams, and other tax-related illegal activities.
In a press release, IRS...more
3/5/2026
/ Enforcement Actions ,
Fraud ,
Fraud Prevention ,
Identity Theft ,
IRS ,
Reporting Requirements ,
Scams ,
Tax Evasion ,
Tax Fraud ,
Tax Returns ,
Tax Scams ,
Taxation ,
Websites ,
Whistleblowers
Following a recent Court of Federal Claims decision, taxpayers may be able to seek tax refunds or abatement of interest and penalties assessed during the COVID-19 pandemic. Taxpayers who accrued interest or penalties between...more
2/27/2026
/ Coronavirus/COVID-19 ,
Court of Federal Claims ,
Filing Deadlines ,
Income Taxes ,
Interest Rates ,
Internal Revenue Code (IRC) ,
IRS ,
Penalties ,
Statute of Limitations ,
Statutory Interpretation ,
Tax Appeals ,
Tax Court ,
Tax Litigation ,
Tax Refunds ,
Tax Relief
In the midst of Congressional consideration of the administration’s FY2026 budget request for the Internal Revenue Service (which was ultimately approved on February 3, 2026), a group of U.S. Senators is raising questions...more
2/12/2026
/ Artificial Intelligence ,
Audits ,
Congressional Oversight ,
Enforcement Actions ,
Federal Budget ,
Federal Funding ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Partnerships ,
Senate Committees ,
Tax Audits ,
Tax Credits ,
Tax Returns ,
Taxation ,
Treasury Inspector General for Tax Administration (TIGTA)
With a dire warning that “[t]ax shelter promoters are watching,” a group of U.S. Senators is questioning a significant decline in Internal Revenue Service investigations of abusive tax schemes as reported in IRS Criminal...more
2/9/2026
/ Appropriations Bill ,
Budget Cuts ,
Congressional Investigations & Hearings ,
Congressional Oversight ,
Criminal Investigations ,
Enforcement Actions ,
Enforcement Authority ,
Federal Budget ,
Government Agencies ,
Inflation Reduction Act (IRA) ,
IRS ,
Tax Avoidance ,
Tax Scams ,
Taxation
The four-day partial government shutdown – which did not impact the Internal Revenue Service – ended yesterday after the House passed, and the President signed, a funding package approved by the Senate just prior to the...more
In the midst of the tax filing season, the Internal Revenue Service remains open for business despite the partial federal government shutdown that went into effect early Saturday morning. The IRS announced on Friday that all...more
As legislators face a January 30 government funding deadline, the House has passed legislation that would further erode the Internal Revenue Service’s annual budget and negatively impact federal tax enforcement. The House...more
1/28/2026
/ Appropriations Bill ,
Budget Cuts ,
Enforcement ,
Enforcement Actions ,
Federal Budget ,
Federal Funding ,
Government Agencies ,
Inflation Reduction Act (IRA) ,
IRS ,
Proposed Legislation ,
Tax Legislation ,
Tax Policy ,
Taxation ,
U.S. House
After a few months of relative calm at the highest levels of the Internal Revenue Service (following turbulence and high-level executive turnover that marked much of 2025), the tax agency is making more leadership changes. ...more
1/26/2026
/ Administrative Appointments ,
Appeals ,
Enforcement Actions ,
Executive Appointments ,
Filing Deadlines ,
Government Agencies ,
Government Efficiency ,
Income Taxes ,
IRS ,
Social Security Administration (SSA) ,
Tax Returns ,
Taxation ,
U.S. Treasury ,
Whistleblowers
As the federal government shutdown passes the two-week mark, and as thousands of Internal Revenue Service employees face furloughs and/or firings, the tax agency has announced a series of significant leadership moves. ...more
10/15/2025
/ Administrative Appointments ,
Appointments Clause ,
CEOs ,
Criminal Investigations ,
Executive Appointments ,
Federal Employees ,
Furloughs ,
Government Agencies ,
Government Shutdown ,
Hiring & Firing ,
IRS ,
Presidential Nominations ,
Senate Confirmation Hearings ,
Social Security Administration (SSA) ,
Taxation ,
Trump Administration ,
U.S. Treasury
A district court in Texas has dismissed a lawsuit filed by the Justice Department to collect an FBAR penalty, concluding for the first time that the Internal Revenue Service’s administrative assessment of an FBAR penalty...more
9/30/2025
/ Constitutional Challenges ,
Department of Justice (DOJ) ,
Enforcement Actions ,
FBAR ,
Foreign Bank Accounts ,
IRS ,
Jury Trial ,
Penalties ,
Reporting Requirements ,
Seventh Amendment ,
Tax Liability ,
Tax Litigation
Leading issues in white-collar criminal defense, government investigations and regulatory compliance were at the center of discussion at our 2025 White-Collar Symposium. Here are some of the key insights attendees took away...more
9/25/2025
/ Artificial Intelligence ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Contractors ,
Fraud Abuse and Waste ,
Government Investigations ,
IRS ,
Medicare Advantage ,
OIG ,
Significant Transnational Criminal Organization ,
State and Local Government ,
Tariffs ,
Trump Administration ,
Whistleblowers ,
White Collar Crimes
The head of the Justice Department’s Tax Division has departed for private practice, just as the planned dismantling of the Tax Division was set to take place. Karen Kelly, who served as acting deputy assistant attorney...more
On August 8, President Donald Trump abruptly removed Billy Long from his position as Commissioner of Internal Revenue, making Long’s tenure the shortest for a Senate-confirmed commissioner in the tax agency’s 162-year...more
8/20/2025
/ Data Privacy ,
Department of Homeland Security (DHS) ,
Government Agencies ,
Hiring & Firing ,
Immigration Enforcement ,
IRS ,
Tax Credits ,
Taxation ,
Trump Administration ,
U.S. Treasury ,
Undocumented Immigrants
More than two decades have passed since the doors of Guantanamo Bay were opened to house alleged terrorists. Those doors remain open, though the number of detainees has dwindled to 15.
In this episode, Mark Denbeaux,...more
The Internal Revenue Service continues to experience significant leadership transition during a period of ongoing internal upheaval and uncertainty. The latest developments are the appointment of Kenneth Kies as the new...more
7/30/2025
/ Administrative Appointments ,
Audits ,
Biden Administration ,
Enforcement ,
Government Agencies ,
IRS ,
Presidential Appointments ,
Tax Appeals ,
Tax Litigation ,
Tax Policy ,
Tax Reform ,
Tax Returns ,
Taxation ,
Trump Administration
A recent report from the Treasury Inspector General for Tax Administration (TIGTA) found that the Internal Revenue Service increased audits of high-income taxpayers during fiscal year 2024, in line with a 2022 Treasury...more
7/21/2025
/ Audits ,
Biden Administration ,
Compliance ,
Earned Income Credit ,
Enforcement Actions ,
Federal Taxes ,
Government Agencies ,
Inflation Reduction Act (IRA) ,
IRS ,
Tax Audits ,
Tax Reform ,
Taxation ,
Treasury Inspector General for Tax Administration (TIGTA) ,
U.S. Treasury
Officials at the U.S. Department of Justice have announced plans to eliminate its Tax Division and relocate its attorneys to other divisions within the department. In existence for more than 90 years, the Tax Division is one...more
7/17/2025
/ Criminal Investigations ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement ,
Enforcement Actions ,
Federal Taxes ,
Investigations ,
Tax Division ,
Tax Evasion ,
Tax Fraud ,
Tax Litigation ,
Taxation ,
White Collar Crimes
The National Taxpayer Advocate has released her Fiscal Year 2026 Objectives Report to Congress, a statutorily-required annual report outlining the objectives of the Office of the Taxpayer Advocate for the upcoming fiscal...more
7/8/2025
/ Audits ,
Budget Cuts ,
Budgets ,
Criminal Investigations ,
Employees ,
Federal Budget ,
Government Agencies ,
Incentives ,
Income Taxes ,
IRS ,
Reduction of Force ,
SBA ,
Tax Reform ,
Taxation ,
Voluntary Reduction in Force ,
Whistleblowers
Former member of Congress and professional auctioneer Billy Long has been formally sworn in as Commissioner of the Internal Revenue Service. Following lengthy delays during his nomination process, Long was confirmed by the...more
The Trump administration is continuing its offensive against the Internal Revenue Service by proposing a $2.5 billion cut to the agency’s budget for FY2026. In the White House’s “skinny budget” released on May 2, the IRS’s...more