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
My recent blog, So, The IRS Has Selected Your Return for Audit, discussed the four types of IRS audits. What factors may trigger an audit of a business’s income tax return?...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
On January 23, 2026, the Brazilian Federal Revenue Service (“RFB”) published Interpretative Declaratory Act (“ADI”) No. 1/2026, which addresses the use of taxes paid abroad by directly or indirectly controlled or affiliated...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
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
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
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
In a recent decision, the New York Tax Appeals Tribunal issued a sharp reminder to ‘snowbirds’ that changing domicile is about substance, not paperwork. In Matter of John J. Hoff & Kathleen Ocorr-Hoff, DTA No. 850209 (N.Y....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
Why do you need an experienced tax attorney when tax issues strike? What do you need to know about communications with the IRS and California's tax agencies?...more
In today's complex and ever-evolving business landscape, tax due diligence has emerged as a critical component of financial analysis and risk management in mergers, acquisitions, and other significant business transactions....more
The Internal Revenue Service (“IRS”) released an update to its plan to transform agency work and improve taxpayer experience. The update to the Strategic Operating Plan provides “an outline of the major projects and outcomes...more
In his State of the Union address, President Joseph Biden targeted tax breaks for corporations and wealthy individuals who use private jets as part of a broader goal to make big corporations and the wealthy pay “their fair...more
On February 21, 2024, the IRS announced plans to begin audits on aircraft that may be used for both business and personal purposes. This push is a part of the IRS’s broader focus on improving tax compliance in high-income...more
Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus on auditing...more
The IRS has been understaffed for many years, and this has led to a decline in the number of audits conducted. The personnel shortage has also made it difficult to keep up with the growing complexity of the tax code and to...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
For many business owners, tax season can be stressful. These four tips can help you lessen the chances of triggering a tax audit....more
After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more
Rule #1: Don’t Panic! Under the Biden Administration’s proposed American Families Tax Plan, there is the possibility of more tax audits, but only for a certain groups of high income people. That’s because more information...more
When a tax return has been selected for office examination, generally the examination of the return will be conducted at the office of the IRS. Normally a taxpayer will find an office examination has begun when he or she has...more
Section 965 audits are on the rise. Taxpayers under section 965 transition tax audits often face significant potential liability exposure. The IRS previously announced an active “campaign” specifically targeting unpaid...more
There is a general misconception about what the IRS can and cannot do. Owing money to the IRS is not like owing any other creditor. The IRS is one of only a few creditors who can seize and sell your home even though state...more
The US Treasury reports that it is expecting the tax gap to rise to approximately $7 trillion over the course of the next decade if left unaddressed. In May 2021, the US Department of the Treasury issued the “THE AMERICAN...more