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Tax Audits Taxation Internal Revenue Service

Fox Rothschild LLP

Group of U.S. Senators Sound Alarm About State of Federal Tax Enforcement

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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

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

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

Epstein Becker & Green

The 409A Horror Show: Don’t Let Year-End Turn Into a Tax Nightmare

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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

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

Civil Tax Fraud: Should 75 Percent Appear Too Small, Be Thankful the IRS Doesn’t Take It All

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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

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

Allen Barron, Inc.

Willful versus Non-Willful Conduct in the Eyes of the IRS

Allen Barron, Inc. on

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

Buckingham, Doolittle & Burroughs, LLC

Ohio State Bar Association Taxation Committee - Sales/Use Tax Subcommittee Report - February 2023

I. EXEMPTIONS - A. Transportation for Hire: Battle Axe Construction v. McClain, Ohio BTA Case No. 2022-559 (October 11, 2022). Exemption denied for truck not used primarily to transport property belonging to others....more

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