Insights

The Internal Revenue Service (IRS) has recently issued multiple notices and proposed regulations focused on combating tax preparer fraud and cracking down on abusive tax schemes facilitated by promoters. IRS Criminal Investigation (IRS CI) has recently issued multiple press releases highlighting its efforts to target tax preparers and promoters as […]

Through its rulemaking authority, the Internal Revenue Service (IRS) has identified several types of transactions as “listed transactions.” As the IRS explains, a listed transaction is any transaction that is, “the same as, or substantially similar to, one that the IRS has determined to be a tax avoidance transaction and […]

Conservation easements have long served as a tax mitigation tool for high-income taxpayers. They also have a long history of drawing scrutiny from the Internal Revenue Service (IRS). While conservation easements provide a legitimate way for high-income taxpayers to reduce their federal tax burden, they also present significant potential for […]

The Internal Revenue Service’s Criminal Investigation division (IRS CI) recently published a report on its COVID-19 fraud enforcement efforts in connection with the third anniversary of the passage of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Passed on March 27, 2020, the CARES Act established several COVID-19 relief […]

The Internal Revenue Service (IRS) conducts most audits and reviews remotely. The IRS is responsible for enforcing more than 150 million taxpayers’ obligations, and, as a result, it simply does not have the resources to visit all delinquent taxpayers in person. As a result, receiving an in-person visit from the […]

If you have been contacted by Special Agents from the Internal Revenue Service’s Criminal Investigation division (IRS CI), one of the first questions you need to answer is, “Why?” IRS CI investigates a broad range of both tax-related and non-tax-related offenses, and determining the specific accusations underlying an IRS CI […]

While IRS Criminal Investigation (IRS CI) targets taxpayers for a broad range of federal offenses, many of its investigations are centered on allegations of tax evasion. These allegations can stem from IRS audits, whistleblower complaints, referrals from other federal agencies, and a variety of other sources, and, regardless of their […]

If you’re like most high-income individuals, you rely on an accountant or other tax professional to prepare your federal tax returns. In doing so, you trust that your tax professional will do the right thing, and accurately calculate your tax liability while taking advantage of the various credits, deductions and […]

Tax planning is crucial for high-income individuals. While the Internal Revenue Code imposes substantial tax liability for those who are in the one percent, it also provides opportunities for high-income taxpayers to lawfully reduce the amount they owe. The Internal Revenue Service (IRS) refers to this as “tax avoidance,” and […]

When companies collect payroll taxes from their employees, they hold their employees’ funds “in trust” pending remittance to the IRS. When companies fail to timely remit their employees’ funds held in trust, they can face substantial liability—including liability for the IRS’ trust fund recovery penalty (TFRP). While the IRS often […]