Under federal law, U.S. taxpayers, whether residing in the U.S. or abroad, are required to disclose their offshore accounts to the federal government annually. While there are minimum account value thresholds, these thresholds will be easily surpassed in most cases. In this article, Texas international tax attorney Lawrence Brown provides […]
In 2025, we published dozens of articles on our blog that provide important insights and practical information for high-income and high-net-worth taxpayers. The Internal Revenue Service (IRS) places particular emphasis on targeting high-income and high-net-worth taxpayers suspected of noncompliance, and facing IRS scrutiny can expose these taxpayers to substantial liability. […]
The IRS’ Voluntary Disclosure Practice is one of a handful of options available to high-income taxpayers that need to proactively resolve high-stakes federal tax controversies. If successful, submitting a voluntary disclosure can substantially mitigate a high-income taxpayer’s liability while also eliminating the risk of facing an audit or investigation related […]
The Internal Revenue Service (IRS) recently published a set of frequently asked questions (FAQs) addressing its ongoing efforts to combat fraud under the pandemic-era Employee Retention Credit (ERC) program. While the IRS’ FAQs focus primarily on a new limitation on the ERC established under the One Big Beautiful Bill (OBBB), […]
On October 1, 2025, the Internal Revenue Service (IRS) announced the launch of a two-year pilot program that is designed “to make Post Appeals Mediation (PAM) more attractive to taxpayers.” Post-Appeals Mediation is one of a handful of options available to individual and corporate taxpayers who disagree with the IRS’ […]
The Paycheck Protection Program (PPP) was a pandemic-era program intended to help companies keep their employees on payroll as the economy faltered. The program was open for portions of 2020 and 2021, and it allowed eligible companies to apply for forgivable government-backed loans from participating financial institutions. Why, then, are […]
Requesting a private letter ruling (PLR) from the IRS’ Office of Chief Counsel is an option for large businesses and international taxpayers seeking to “determine the tax treatment of a specific situation” without facing an audit. It is one of several pre-filing and pre-resolution audits that are available to eligible […]
For large businesses and international taxpayers, the IRS’ Pre-Filing Agreement (PFA) program provides a way to “seek an agreement on issues likely to be disputed in post-filing audits.” Eligible taxpayers can use the PFA to address tax concerns related to specific transactions, or they can use the PFA to seek […]
For large business and international taxpayers, filing a return with the Internal Revenue Service (IRS) will frequently lead to post-filing scrutiny. This scrutiny can take a variety of forms, from informal inquiries to invasive audits and criminal tax investigations. When facing post-filing scrutiny (or the risk of post-filing scrutiny), a […]
The Internal Revenue Service (IRS) offers a variety of options to large business and international taxpayers that need to resolve tax controversies at the pre-filing or pre-audit stage. These options are specifically tailored to taxpayers that fall under the jurisdiction of the IRS’s Large Business and International (LB&I) Division, which […]