The Internal Revenue Service’s Criminal Investigation Division (IRS CI) conducts investigations focused on all forms of criminal tax evasion and tax fraud. But, its enforcement jurisdiction is also much broader, and it routinely works with the U.S. Department of Justice (DOJ) and other federal authorities to substantiate charges for a […]
The Internal Revenue Service (IRS) confirmed this month that it will be classifying syndicated conservation easements as abusive tax transactions going forward. While syndicated conservation easements have long been a red flag for the IRS, this new development increases the risks for taxpayers who rely on syndicated conservation easements to […]
The Internal Revenue Service (IRS) released its “tax gap” projections for the 2022 tax year on October 10, 2024. As the IRS explains in its News Release, the tax gap, which is an estimated $696 billion, “reflects the difference between projected ‘true’ tax liability and the amount of tax that […]
Even with 2025 fast approaching, Employee Retention Credit (ERC) fraud enforcement remains a top priority for the Internal Revenue Service (IRS). As we have discussed previously, the IRS has identified billions—and potentially trillions—of dollars in taxpayer losses resulting from ERC fraud, and it is now working to claw back as […]
The Internal Revenue Service (IRS) is targeting high-income and high-wealth taxpayers. Over the past year, the IRS has launched two separate initiatives focused specifically on enforcing high-income and high-wealth taxpayer compliance. It has also made clear that it is prioritizing enforcement in several areas that are of particular concern to […]
With football season underway, the Internal Revenue Service’s Criminal Investigation Division (IRS CI) is warning U.S. taxpayers to make sure they have a clear understanding of the tax implications of sports gambling. As IRS CI explains, “Individuals who engage in sports betting activities are required to report their winnings on […]
As the Internal Revenue Service (IRS) continues to focus on uncovering Employee Retention Credit (ERC) fraud and recovering fraudulent credits and refunds from taxpayers, it is also devoting resources to targeting so-called “promoters.” While the IRS’ definition of “promoters” includes bad actors who operated ERC filing scams during and after […]
While facing a federal tax audit can be risky in any circumstance, it can be especially risky if you have concerns about tax code compliance. For high-income and high-net-worth taxpayers, non-compliance with the Internal Revenue Code can create substantial exposure—including exposure to liability for interest and penalties. With this in […]
If you are like most high-income and high-net-worth taxpayers, you rely on professionals to help make sure you pay what you owe (while also making sure you pay as little as possible). So, what happens if one of your tax professionals makes a mistake? Are you liable to the Internal […]
On August 15, 2024, the Internal Revenue Service (IRS) announced that it is reopening the Employee Retention Credit (ERC) Voluntary Disclosure Program, effective immediately through November 22, 2024. As IRS Commissioner Danny Werfel explains in the IRS’ News Release, “[t]he limited reopening of the Voluntary Disclosure Program provides an opportunity for […]