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Is it too late to correct past FBARs and file amended returns with the IRS? The net is closing in on U.S. taxpayers with unreported or under-reported domestic and offshore income and assets. The IRS has increased audits in...more
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
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
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
It is important to understand the step doctrine and how it applies to IRS audits and state tax investigations, including California tax audits. The "step doctrine" is a concept not directly found in federal or California...more
Many US taxpayers still have questions regarding offshore accounts and FBAR filing requirements and compliance. Is there a genuine risk their activities (or lack of compliance) will come to light? The definition of a US...more
On December 13, 2023, the IRS revealed a revamped leadership structure, introducing Chief Information Officer and Chief Operating Officer positions to leverage technology more effectively. The move aligns with IRS...more
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
New Funding, New Focus - With some $80 billion in initial funding from the Inflation Reduction Act (IRA), the Internal Revenue Service (IRS) began ramping up taxpayer services, issue resolution planning, compliance and...more
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
On 10/12/23 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 tax years...more
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
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
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
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
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
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
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
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
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
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
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
When the Inflation Reduction Act was passed last year, the legislation included massive funding increases for the Internal Revenue Service (IRS). The initial narratives regarding the funding increases focused primarily on...more
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
The IRS plans to audit the wealthiest corporate, partnership, and individual taxpayers to achieve some of its main objectives in 2022. In his recent testimony before Congress, IRS Commissioner Charles P. Rettig...more