What should you do if you discover that you made mistakes on last year’s federal returns when doing your taxes in 2025? Or, what if you already knew that you made mistakes, and you want to address them so that you are not at risk in the event of an […]
With Tax Day just around the corner, now is a time of year when many people, particularly high-income and high-net-worth taxpayers, begin to have concerns about the possibility of facing an IRS audit. Even if you do your best to meet your federal tax obligations—and even if you rely on […]
For high-income taxpayers who are facing collection by the Internal Revenue Service (IRS), failing to take decisive action can have significant financial consequences. Reversing and recovering from IRS collection actions can be far more difficult (and costly) than preventing them in the first place, and facing IRS collection presents additional […]
If you are facing substantial tax debt in 2025, you will want to take a proactive approach to dealing with the Internal Revenue Service (IRS). The IRS has various options for enforcing taxpayers’ financial obligations, and tax liens, levies, and other collection mechanisms can present significant challenges and hardships. In […]
Internal Revenue Service (IRS) audits can present substantial risks, especially for high-income and high-net-worth taxpayers. Not only can revenue agents impose liability for back taxes, interest, and penalties, but if they uncover apparent evidence of an intentional unlawful tax avoidance scheme, they can engage Special Agents from IRS Criminal Investigation […]
Under federal law, U.S. taxpayers who hold qualifying offshore accounts (and certain other foreign financial assets) must report these assets to the U.S. Treasury on an annual basis. In many cases, taxpayers must file two separate forms—with two separate federal entities—to meet their reporting obligations. One of these forms, the […]
Each year, we publish dozens of articles with insights for high-income and high-wealth U.S. taxpayers on our blog. This past year was no exception. Here is a look back at some of the key compliance insights Texas IRS dispute lawyer Lawrence Brown shared in 2024: Resolving Offshore Account Disclosure Violations […]
For businesses that claimed the Employee Retention Credit (ERC) or received a Paycheck Protection Program (PPP) loan or Economic Injury Disaster Loan (EIDL), facing scrutiny from the Internal Revenue Service (IRS) remains a very real concern. The IRS is continuing to aggressively target pandemic-era fraud heading into 2025—pursuing audits and […]
The Internal Revenue Service (IRS) recently released two end-of-year reports highlighting its enforcement efforts during the 2024 fiscal year. In the IRS’s own words, these reports reflect the agency’s “global reach” and “billion-dollar impact” and “outlin[e] key milestones in criminal investigations . . . and advancements in digital modernization that […]
It’s the end of another year. While this is a time when many people do some last-minute tax planning, it is also a time when many people make all-too-common tax mistakes. The Internal Revenue Service (IRS) is intimately familiar with these mistakes—and it looks for them when examining taxpayers’ returns […]