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
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
Le Conseil d’Etat tranche la question de l’ordre d’imputation des déficits reportables en avant : il retient une imputation selon un ordre strictement chronologique et en tire les conséquences pour l’application des règles de...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
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
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 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
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
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
Did you know that the number of California FTB audits is increasing when compared to the trend of IRS audits in 2025? The California Franchise Tax Board, or FTB, has recently invested in advanced data processing systems and...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
What is willful blindness according to the IRS? How is this important in tax cases involving unreported or under-reported income, disclosure of offshore assets and income, FinCEN Form 114 (more commonly referred to as an...more
It's astonishing how many business owners undervalue accounting and its profound financial impact on business operations, transactions, taxation, and profit. An effective accounting strategy captures the information required...more
What constitutes willful versus non-willful conduct in the eyes of the IRS? Why is this distinction important to the agency, especially regarding international disclosures and taxable events? We are often asked about how...more
What does the recent OTA ruling tell you about a California tax audit? What can we learn from the results of an investigation by the Office of Tax Appeals (OTA) into the practices of a California tax agency? Why do you need...more
El 12/10/23 se anunciaron nuevas proyecciones de la brecha fiscal para los años fiscales 2020 y 2021 que muestran que la brecha fiscal bruta proyectada aumentó a $688 mil millones en el año fiscal 2021, un aumento de más de...more
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
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
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