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Audits Tax Planning

Freeman Law

Centralized Partnership Audit Regime (CPAR) and a Trap for the Unwary

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Centralized Partnership Audit Regime (CPAR) is a somewhat new regime that followed TEFRA. Congress promulgated CPAR as part of the Bi-partisan Budget Act of 2015. For taxable years beginning in 2018, CPAR is the controlling...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

McDermott Will & Emery

“Voluntary” in Name Only? New Jersey Introduces Transfer Pricing Initiative

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The New Jersey Division of Taxation (Division) has announced a “voluntary” transfer pricing initiative beginning June 15, 2022, and continuing through March 2, 2023. According to the Division, the initiative is targeted...more

Cadwalader, Wickersham & Taft LLP

Democrats Propose Mark-to-Market Tax and Increased Audits on High-Net-Worth Individuals

Democrats at both the federal and state levels are proposing a “mark-to-market” tax and legislation that would mandate more audits on high-income taxpayers....more

Morgan Lewis

Beware States Offering Unilateral Advance Pricing Agreements for Transfer Pricing

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As state revenue agencies train their auditors in traditional IRC §482 transfer-pricing methodologies or outsource transfer-pricing audits to third-party specialists, a recent initiative by the Indiana Department of Revenue...more

McDermott Will & Emery

[Webinar] Navigating PPP Loan Forgiveness (Part 2) - August 20th, 3:00 pm - 4:00 pm EDT

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Join McDermott and BDO on Thursday, August 20 to hear about the latest updates concerning the Paycheck Protection Program (PPP). Our multi-disciplinary panel will cover the most pressing issues as of August 2020, including: ...more

Foodman CPAs & Advisors

How does IRS Identify Cases with Audit Potential?

Understanding how the IRS identifies cases that have audit potential can be learned from the CONGRESS OF THE UNITED STATES (CONGRESSIONAL BUDGET OFFICE) Report released on July, 2020: Trends in the Internal Revenue Service’s...more

Foodman CPAs & Advisors

Audit Time for High Income Individuals and their Companies has arrived

On a webinar hosted by the New York University Tax Controversy Forum on June 18, 2020, Douglas O’Donnell (head of the IRS Large Business and International Division/IRS-LBI) stated that the IRS will  begin a new campaign to...more

Foodman CPAs & Advisors

Forensic Accountants Should Be an Integral Component of PPP Loan Audits

The published goal of the Paycheck Protection Program (PPP) loan program is to assist small businesses to remain open during the Covid-19 crisis and to reduce the rate of unemployment.  The loans provide a direct incentive...more

Foodman CPAs & Advisors

What can Borrowers do to prepare for PPP Loan Program Audits?

Treasury Secretary Steven Mnuchin has stated that Businesses that borrow money through the PPP may expect compliance audits before their loans are forgiven.  Many banks, with the encouragement of the U.S. Treasury, “skipped”...more

Foley Hoag LLP - Cannabis and the Law

Treasury Report Recommends Increased Audits of Cannabis Companies and Highlights Potential Section 280E Relief

On March 30th, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report which concluded, based on its estimates, that the IRS could have collected significant additional tax revenue from cannabis...more

Seyfarth Shaw LLP

Section 280E – Why Are We Still Having This Discussion?

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If you are in the cannabis industry, you should already know Section 280E of the Internal Revenue Code. It consists of only one sentence...more

Carlton Fields

US Treasury and IRS Targets for Audit

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On October 8, 2019, the U.S. Department of Treasury and the IRS released the 2019-2020 “Priority Guidance Plan” for the 12-month period running from July 1, 2019, through June 30, 2020. The plan sets out the agencies’...more

Foodman CPAs & Advisors

What if the IRS wants to “Audit” your Tax Returns?

The IRS might want to audit (also known as a review or an examination) an Individual Taxpayer’s accounts and financial information to verify that the information that the Individual Taxpayer is reporting is compliant with the...more

Troutman Pepper

Do You Know Who Your Partnership Representative Is? - Tax Update Volume 2019, Issue 1

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The new partnership audit rules apply to tax years beginning in 2018. While the new rules eliminate the need for a tax matters partner, that role is replaced with a new role called the partnership representative (PR). ...more

Foodman CPAs & Advisors

IRS can start asking questions about Campaign Issues. Have your Audit Plan Ready!

Foodman CPAs & Advisors on

On January 31, 2017, the IRS Large Business and International Division (LBI) announced a compliance campaign strategy to redefine large business compliance work and build a supportive infrastructure inside the LBI. ...more

Bracewell LLP

Bracewell Tax Report: February 2018 #2

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The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

Carlton Fields

New Partnership Audit Rules – Plan Ahead Before the Tax Bill Arrives

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A new set of rules for partnership audits (New Audit Rules), which generally take effect January 2018, fundamentally alter the manner in which the Internal Revenue Service (IRS) will conduct audits of partnerships,...more

McDermott Will & Emery

Focus on Tax Strategies & Developments - April 2017

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Impact of Country-By-Country Reporting on Multinational Enterprises - Perhaps the most challenging component of the Base Erosion and Profit Shifting (BEPS) initiative adopted by the OECD and G20 countries, Action 13...more

Bradley Arant Boult Cummings LLP

Beware New IRS Partnership/LLC Audit and Assessment Rules

You may have heard that the IRS’s ability to audit partnerships (including multi-member LLCs) will be greatly enhanced due to changes made by the recent Bipartisan Budget Act of 2015. The new rules apply to tax years...more

Troutman Pepper

The Game Has Changed: Congress Enacts Changes to IRS Partnership Audit Rules That Could Force Partnerships to Pay Tax - Tax Update...

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The Bipartisan Budget Act will allow the IRS to collect taxes associated with audit adjustments at the partnership level, rather than passing adjustments through to the individual partners, effectively imposing entity-level...more

Dorsey & Whitney LLP

Minnesota Income Tax Residency Law— Recent Developments and Planning Considerations

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On April 16, 2014, the Minneapolis Star Tribune published an article by Adam Belz titled, “Minnesota’s wealthy caught in a tight tax net over residency.” The article discussed the Minnesota Department of Revenue’s approach to...more

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