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
The IRS announced a new campaign to audit high-net-worth taxpayers claiming business deductions for the use of private jets. Using some of the $80 million allocated for enhanced enforcement in the Inflation Reduction Act of...more
The US Department of the Treasury has recently reinforced the progress on enforcement, specifically how the IRS is focused on tax evasion targeting and the targeting of high-income individuals and entities. The IRS has...more
Large partnership audits are a cornerstone of the IRS’ revamped enforcement priorities. As part of its Large Partnership Compliance program, the agency recently announced that it is rolling out audits of 75 large partnerships...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
On September 8, 2023 the IRS announced a sweeping effort to focus enforcement efforts on high-income individuals, partnerships, and corporations. On September 20, 2023 the IRS announced that it will establish a special...more
The Bipartisan Budget Act (BBA) was signed into law by President Barack Obama in 2015 and fundamentally changed the way partnerships are audited. Under the BBA, the IRS generally assesses and collects any understatement of...more
On November 2, 2015, the Bipartisan Budget Act (“Act”) was signed into law by President Barack Obama. One of the many provisions of the Act significantly impacted: (i) the manner in which entities taxed as partnerships are...more
Throughout November, various Multistate Tax Commission committees held virtual annual meetings (due to COVID). In this episode, Matt Hunsaker runs down the highlights from each meeting, including technical corrections to...more
In remarks at the NYU Tax Controversy Forum in June, the IRS discussed two new IRS return examination campaigns. Ms. Tamera Ripperda, the commissioner of the Tax Exempt and Government Entities (TEGE) Division who previously...more
The Internal Revenue Service ("IRS") announced that as soon as it reopens its collection and examination functions on July 15, it will immediately begin the examination of hundreds of high-income individuals and private...more
Conforming- About sixty years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 14 – October 18, 2019. October 15, 2019: The IRS published a news release that...more
• U.S. and non-U.S. investment funds that are required to file, or file, a U.S. partnership tax return (Internal Revenue Service (IRS) Form 1065) are generally subject to a new U.S. partnership audit regime that permits the...more
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, with emphasis on how such developments impact the energy, technology...more
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
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
Amanda Nussbaum, a partner in the Tax Department and a member of the Not-for-Profit Group at Proskauer, chairs a comprehensive seminar each fall for non-profits to discuss current developments and topics of interest related...more
On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more
While the news is filled with the ongoing tax reform activity in Congress, there is one tax change that is already in place to take effect January 1, 2018 – the repeal and replacement of the tax audit regime for partnerships....more
The Bipartisan Budget Act of 2015, as modified by the Protecting Americans from Tax Hikes Act of 2015, resulted in a fundamental change in the way the U.S. Internal Revenue Service (IRS) will conduct audits of collective...more
As you’ve surely heard by now, the Bipartisan Budget Agreement of 2015 (“BBA”) enacted new IRS procedures for partnership audits for tax years beginning on or after January 1, 2018. The new audit rules allow the IRS to...more
The U.S. Treasury Department and the Internal Revenue Service (“IRS”) recently reissued 277 pages of proposed regulations and a preamble (REG-136118-15) regarding the new centralized partnership audit rules enacted as part of...more
According to statistical data released by the IRS earlier this year, the examination rate for partnership tax returns has been increasing significantly over the last couple of years; of course, this includes returns filed by...more