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Tax Audits Audits

Rivkin Radler LLP

Applying the Federal Priority Statute to The Attorney as Client’s “Corporate Executive”

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Over their career, every tax practitioner has had many client-taxpayers against whom a government’s taxing authority – be it federal, state, or local – has asserted and then assessed a tax deficiency. There are many...more

Genova Burns LLC

Jersey City Issues Executive Order on PILOT Audits: What Developers and Owners Need to Know

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In an action that may signal a challenging environment for tax abatements in Jersey City, newly elected Jersey City Mayor James Solomon recently signed an Executive Order on January 21, 2026 launching a comprehensive audit of...more

Skadden, Arps, Slate, Meagher & Flom LLP

A Depleted IRS May Turn to Expedited Processes to Work Off Dispute Backlog

By any measure, 2025 was a tumultuous year for the Internal Revenue Service (IRS), leaving a slimmed-down organization struggling to implement new priorities and a workforce trying to catch its breath in the face of dizzying...more

Opportune LLP

IRS Tax Controversy Guide: Navigating the Process from Notice to Resolution

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Tax controversy is a term that describes disputes between taxpayers and taxing authorities, most commonly the Internal Revenue Service (IRS), regarding the amount of tax owed or the application of tax laws. These...more

Procopio, Cory, Hargreaves & Savitch LLP

GAO Report Signals Intensified IRS Scrutiny of Puerto Rico Act 60 Residents

The U.S. Internal Revenue Service (IRS) appears to be entering a new and far more aggressive phase of enforcement focused on taxpayers claiming Puerto Rico residency and Act 60 (formerly Act 22) incentives or benefits. The...more

Vorys, Sater, Seymour and Pease LLP

Ohio Legislature Proposes Changes to the Taxpayer Bill of Rights

The General Assembly has recently proposed legislation to update Ohio’s Taxpayer Bill of Rights. House Bill 613 (H.B. 613) has been introduced but not yet assigned to a committee for review. The Bill offers several sweeping...more

Rivkin Radler LLP

Escape from New York – It’s Not That Easy

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It’s not at all unusual to encounter the owner of a New York business who dreams about leaving the State. The reasons often given for the desired move include, among others, the cost of doing business in New York, the State’s...more

Hanson Bridgett

No Joke. California Office of Tax Appeals Rules Against Comedian in Residency Dispute

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California residents seeking to change their residency status and avoid California tax must be prepared to substantiate their relocation. Simply moving to another state is not enough to relinquish California residency and tax...more

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Procedural Reforms Aim To Allow Early Resolution of Controversies With Businesses

Over the past few months, interest and attention in the world of U.S. tax has been focused on the OBBBA — the One Big Beautiful Bill Act. However, significant administrative and procedural changes have also occurred at the...more

Vinson & Elkins LLP

Planning for IRS Audits in an Era of Uncertainty

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In its ongoing crusade against so-called “basis-shifting” transactions, the Internal Revenue Service has created widespread uncertainty regarding the tax treatment of routine transactions. For example, last year, the IRS...more

Fox Rothschild LLP

IRS Increased Audits Of High-Income Individuals During FY2024, But Future Of Initiative Under New Administration Is Doubtful

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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

Farella Braun + Martel LLP

REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations

Welcome to EO Radio Show – Your Nonprofit Legal Resource. Many nonprofits today are worried about recent federal actions that may bring governmental scrutiny to their stated charitable mission and activities, such as audits,...more

Arnall Golden Gregory LLP

April Rules Day: Georgia Department of Revenue Streamlines Film Tax Credit Audit Rules

Effective March 12, 2025, the Georgia Department of Revenue (“GADOR”) issued Policy Bulletin IT-2025-01 implementing various updates to its Mandatory Film Tax Credit Audit Program....more

McDermott Will & Schulte

Soaring New Heights: The IRS’s Crackdown of Aircraft Usage by Corporations and High-Income Earners

The Internal Revenue Service (IRS) has announced plans to initiate dozens of new audits this spring in an attempt to limit personal usage of corporate aircraft. These audits will focus primarily on “highest risk” corporations...more

Pillsbury Winthrop Shaw Pittman LLP

IRS Ramps Up Audits on Corporate Aircraft Use for High-Net-Worth Individuals and Affiliated Entities

The Internal Revenue Service (IRS) is increasing audits on corporate aircraft use for high-net-worth individuals, large corporations and complex partnerships as part of its new initiative using Inflation Reduction Act funding...more

McDermott Will & Schulte

IRS Strengthens Its Large Partnership Audit Teams

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

A&O Shearman

California Enacts New Partnership Audit Rules

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On September 23, 2018, Senate Bill 274, Administration of taxes: notice of deficiency assessment (SB-274), was signed into law by Governor Jerry Brown of California. With the enactment of SB-274, California has adapted its...more

Snell & Wilmer

IRS Audit Techniques Guide Provides Helpful Reminders for Sponsors of NQDC Arrangements

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Last summer the Internal Revenue Service updated its Audit Techniques Guide (“ATG”) for nonqualified deferred compensation arrangements. While the ATG provides little instruction on how the IRS will review nonqualified...more

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