News & Analysis as of

Internal Revenue Service Enforcement

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Fox Rothschild LLP

IRS Increases Pressure on Businesses That Claimed Employee Retention Tax Credits

Fox Rothschild LLP on

The Internal Revenue Service (IRS) recently issued a news release identifying five new signs that a business’s Employee Retention Tax Credit (ERC) may be incorrect. It has also begun issuing a third round of letters denying...more

Akin Gump Strauss Hauer & Feld LLP

CryptoLink - June 2024 Updates

CryptoLink is a compilation of news stories published by outside organizations. Akin aggregates the stories, but the information contained in them does not necessarily represent the beliefs or opinions of the firm. Akin's...more

Arnall Golden Gregory LLP

Q&A With Allison Raley: Defending Against Government Investigations

Q: What are the primary areas of focus in your practice related to government investigations? A: My practice primarily focuses on defense against enforcement actions brought by regulatory bodies such as the Office of Foreign...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

Lathrop GPM

Regulators Examining Interested Party Transactions in Healthcare and in other Nonprofits

Lathrop GPM on

State attorneys general, the IRS, and other regulators are focused on “interested party” (conflict-of-interest) transactions in the healthcare and nonprofit sectors. While these transactions are generally permissible and may...more

Pillsbury Winthrop Shaw Pittman LLP

Don’t Forget to File (Accurately): 2024 Brings Heightened IRS and DOJ Focus on Non-Filers and Digital Assets

The IRS has increased funding for collection and enforcement, with a stated focus on high income non-filers and digital assets (among other areas). The DOJ has also emphasized a focus on digital assets, and the Department...more

Fox Rothschild LLP

Millionaires, Corporate Jets and Crypto: IRS Unveils New Enforcement Initiatives

Fox Rothschild LLP on

Thanks to a dramatic increase in funding courtesy of the Inflation Reduction Act of 2022, the Internal Revenue Service recently announced several new, high-profile enforcement initiatives designed to generate significantly...more

BakerHostetler

Weekly Blockchain Blog - March 2024

BakerHostetler on

Crypto Exchanges Launch Institutional Platform, LATAM Stablecoin - A major U.S. cryptocurrency exchange recently announced the launch of an institutional platform “aimed at institutions, asset managers, hedge funds and...more

Fox Rothschild LLP

IRS to Focus on High-Income Earners Who Have Not Filed Tax Returns Since 2017

Fox Rothschild LLP on

The IRS expects to send out over 125,000 collection letters to high-income taxpayers who did not file one or more federal income tax returns between 2017 and 2021. As part of the new collection initiative, approximately...more

DarrowEverett LLP

The Brass Tacks: IRS Creates Process for Withdrawing ERC Claims

DarrowEverett LLP on

The Internal Revenue Service (“IRS”) recently granted employers a means to avoid interest and penalties on inappropriately taken Employee Retention Tax Credit (“ERC”) claims. This surely will come as a relief to taxpayers who...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

Lippes Mathias LLP

IRS Halts Processing of ERC Claims Citing Extensive Fraud and Abuse

Lippes Mathias LLP on

In an extraordinary development, the IRS has halted its processing of Employee Retention Credit (“ERC”) refund claims as it struggles to keep up with the massive number of claims filed within the last several months. The...more

Buchalter

FBARs, FATCA, and Foreign Nationals: Where are We Headed?

Buchalter on

There has been a legal shakeup this summer in the world of “FBARs”—Reports of Foreign Bank and Financial Accounts. New developments have been popping up nearly every week, whether from a court decision, as a result of a...more

BakerHostetler

IRS Enforcement Efforts in Puerto Rico Gaining Steam - Wave of Cases Expected

BakerHostetler on

Long-awaited enforcement actions may be coming soon for those who took advantage of the lucrative tax breaks offered by the Commonwealth of Puerto Rico without meeting the requirements. Prosecutions may also follow for...more

Husch Blackwell LLP

IRS Signals Increased Reliance on Partnership Anti-Abuse Rules

Husch Blackwell LLP on

Speaking at a Practicing Law Institute program on April 25, Internal Revenue Service (IRS) lawyer Clifford Warren indicated that the IRS has been using the anti-abuse rule of Treasury Regulation Section 1.701-2 to scrutinize...more

DarrowEverett LLP

The Show Must Go On: Entertainer-Employee Classification Takes Center Stage for Venues

DarrowEverett LLP on

It’s spring 2023, live entertainment is back, and perhaps so is the Internal Revenue Service (“IRS”). The Inflation Reduction Act, signed into law on August 16, 2022, authorizes $80 billion in funding for the IRS over the...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

Skadden, Arps, Slate, Meagher & Flom LLP

What To Expect From the IRS’ $80 Billion Strategic Operating Plan

In August 2022, the Inflation Reduction Act (IRA) was signed into law, allocating approximately $80 billion to the Internal Revenue Service (IRS) over the next decade to improve the way it serves the public....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

Buckingham, Doolittle & Burroughs, LLC

Employee Retention Credits – Supporting eligibility becomes crucial amidst aggressive promotion of ERC claims as Internal Revenue...

The employee retention credit (ERC) can be a tremendous boon for eligible employers to claim substantial cash refunds for keeping their employees on the payroll during the COVID-19 pandemic. To qualify, the employer must have...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

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden’s 2023 Insights – Five Critical Areas for the Year Ahead

The pandemic’s impact may be subsiding, but businesses are encountering new challenges across the globe, including the potential for an economic retrenchment, rising interest rates, shifting regulatory and litigation...more

McDermott Will & Emery

Update on IRS Enforcement Efforts

McDermott Will & Emery on

We frequently post about the Internal Revenue Service’s (IRS) tax enforcement trends and announcements. Prior examples from this year include the release of a five-year strategic plan emphasizing enforcement, the plan to hire...more

BakerHostetler

IRS Warns: Hundreds of Crypto Criminal Tax Cases Coming Soon; Hiring of 300 Special Agents Means More to Follow

BakerHostetler on

Takeaways: ..2022 IRS Criminal Investigation Annual Report highlights significant prosecutions and identifies cryptocurrency as an area of top priority heading into 2023. ..Criminal Investigation Chief Jim Lee...more

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