Podcast - Betty: Glamour en pasarela, caos contable y tributario
REFRESH Five Tax Traps for Business Lawyers Advising Nonprofit Organizations
How to Prepare for the IRS’s “New 90-Day Pre-Examination Compliance Pilot” Audit Process
Jones Day Presents: LB&I Examination Strategies: Responding to IDRs
Jones Day Presents: LB&I Examination Strategies: Process Overview
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Examination
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
The Internal Revenue Service (“IRS”) audits 1% to 2% of small business income tax returns annually for one of two reasons: (1) something about the return (or information reported on the return) flagged the return for a closer...more
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
There are over 150 types of penalties in the Internal Revenue Code (IRC). One frequent penalty that the Internal Revenue Service (IRS) asserts is the accuracy penalty under IRC Section 6662....more
If you have received an IRS Letter of Notification advising you that your return has been selected for audit, the most important thing to understand is this: the audit has already begun. The first communications with the IRS...more
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
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
A couple of years ago, I wrote a blog about the importance of sending any correspondence to the Internal Revenue Service via Registered or Certified Mail or by an approved overnight courier, rather than relying solely on the...more
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
Earlier this year, we unpacked the elements of tax fraud, how the Internal Revenue Service (IRS) approaches fraud in civil and criminal settings, and the penalties and consequences that can follow. That discussion focused on...more
How might marrying a non-US citizen affect your taxes? What are some of the hidden issues that the IRS, California, and other state tax agencies may raise in an audit?...more
Working on an IRS audit is hard enough. But what’s even harder? When you discover the plan sponsor disposed of—or claims to have disposed of, the very records the IRS is demanding....more
Is the burden of proof on the IRS during an Audit? It might shock you to learn that the burden of proof in an IRS audit, and in most dealings with the IRS, lies with the U.S. taxpayer, not the IRS....more
As year-end approaches, it is an opportune time for companies to run an internal audit of their nonqualified deferred compensation plans to flag any potential violations of IRC Section 409A (“Section 409A”)....more
For the last decade, the IRS has proactively asserted discretionary civil tax penalties that can be as high as 40 percent of the proposed tax liability. Oftentimes, the IRS has used penalties as bargaining chips to get...more
For restaurant owners going through a divorce, one of the most contentious financial issues can be non-reporting income, particularly cash earnings. Courts require full financial disclosure, and failure to accurately report...more
As we discussed a few weeks ago, the IRS is charged with enforcing the U.S. federal tax laws; i.e., it is responsible for processing tax returns and for collecting taxes. As part of its collection function, the agency may...more
A decade ago, the IRS audited and brought cases against numerous taxpayers who claimed residency in the U.S. Virgin Islands to take advantage of a highly touted benefit whereby bona fide Virgin Islands residents could claim a...more
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
Why do you need an experienced tax lawyer for a California business tax audit? What are some of the genuine risks during an audit of your business or professional practice?...more
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
What happens if you are accused by the IRS, the FTB, or another California tax agency regarding omissions, fraud, or false information on a tax return? The short answer is simple: failure to make a full, transparent, and...more
The IRS Large Business & International (LB&I) Division published an Interim Guidance Memorandum (IGM) on July 23, 2025, implementing three changes to current LB&I audit procedures. Specifically, the IGM (1) removes the...more
Mistakes happen, including when it comes to reporting and paying taxes. And for taxpayers and their advisors, those mistakes can lead to costly consequences, as the Internal Revenue Code (“Code”) allows the Internal Revenue...more
Tax developments - IRS issues interim guidance to streamline LB&I audit procedures and promote alternative settlement programs - Significant updates from the IRS Large Business & International (LB&I) Division will take...more